Guidance for Auditing

Risk Management

Plans/Programs 

under Clean Air Act 

Section 112(r)

United States

Environmental Protection

Agency

Office of Solid Waste

and Emergency Response

(5104)

EPA 550-B99-008

August 1999

www.epa.gov/ceppo/

NOTICE 

This document is intended solely for the guidance of 

government personnel. It is not intended and cannot be

relied upon to create rights, substantive or procedural,

enforceable by any part, in litigation with the United States.

The Agency reserves the right to act at variance with this

guidance and change it at any time without public notice. 
Guidance for Auditing Risk Management Plans & Programs

Acronyms Used in This Guidance

AIChE American Institute of Chemical Engineers

ANSI American National Standards Institute

API American Petroleum Institute

ASME American Society of Mechanical Engineers

CAA Clean Air Act

CBI Confidential Business Information

CCPS Center for Chemical Process Safety

CFR Code of Federal Regulations

D & B Dun and Bradstreet

EPA Environmental Protection Agency

EPCRA Emergency Planning and Community 

Right-to-Know Act

ERNS Emergency Response Notification System

HAZWOPER Hazardous Waste Operations and Emergency

Response

LEPC Local Emergency Planning Committee

NCP National Contingency Plan

NFPA National Fire Protection Association

NRS National Response System

OSHA Occupational Safety and Health Administration

PHA Process Hazard Analysis

PPE Personal Protective Equipment

PSM Process Safety Management

RMP Risk Management Plan

SARA Superfund Amendments and Reauthorization 

Act

SERC State Emergency Response Commission
Table of Contents

TABLE OF CONTENTS

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

Guidance Purpose and Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

Interrelated Opportunities for Accident Prevention . . . . . . . . . . . . . . . . . . . . .4

Risk Management Program Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Table 1: RMP Program Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Developing an RMP Audit Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

Objective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

Approaches to an RMP Audit: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

How to Use Reviews / Audits / Inspections . . . . . . . . . . . . . . . . . . . . . . .10

The RMP Audit Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

Step (1) Selecting Facilities for RMP Audits . . . . . . . . . . . . . . . . . . . . . . . . . .15

Step (2) Off-site Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

Collecting Background Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

Table 2: Background Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Planning the Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Prepare Audit Staff and Plan Logistics . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Table 3: Potential Audit Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Step (3) At the Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Entering the Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Opening Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Collecting and Analyzing Information . . . . . . . . . . . . . . . . . . . . . . . . . . .22

Personal Protective Equipment (PPE) . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Exit Briefing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Step (4) Concluding Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

Follow-up Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

Audit Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

Step (5) After-Audit Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27

Preliminary Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27

Final Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27

ANNEX A: Site Safety Plan for On-Site Activities

ANNEX B: Audit Report

ANNEX C: Audit Checklist 

ANNEX D: Risk Management Program and OSHA Process Safety Management: 

List of Regulated Substances 
Guidance for Auditing Risk Management Plans & Programs
1

Introduction
Guidance for Auditing Risk Management Plans & Programs

2
3

Introduction

Guidance Purpose and

Background

GUIDANCE PURPOSE AND BACKGROUND 

Purpose

This document provides guidance for implementing agencies

that are required by the Risk Management Program regulation (40 CFR 68.220) to conduct audits. It is designed as a

tool for auditors reviewing industry compliance with the Risk

Management Program regulation. However, this guidance

does not reflect all requirements that a stationary source

must meet to be in compliance with the regulation.

Background

The Environmental Protection Agency (EPA) works closely

with stakeholders to reduce the likelihood and severity of

chemical accidents. 

Several important planning and legislative initiatives have

been introduced since 1968. These include the National

Contingency Plan (NCP) (started in 1968), EPA's voluntary

Chemical Emergency Preparedness Program started after the

December 1984 accident in Bhopal (India), the Emergency

Planning and Community Right-to-Know Act of 1986

(EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as

amended in 1990. These initiatives address the entire safety

continuum dealing with chemical accident preparedness,

response, and prevention.

In this document "RMP" denotes the Risk Management Plan,

which summarizes the source's risk management program and

is submitted to EPA.
Guidance for Auditing Risk Management Plans & Programs

4

INTERRELATED OPPORTUNITIES FOR CHEMICAL

ACCIDENT PREVENTION: Chemical Safety Audits,

Accident Investigations, General Duty, and RMP Audits

From a government point of view, chemical accident prevention involves: (1) working with sources to improve their

chemical safety management program, and (2) encouraging

communities to coordinate risk reduction activities with facilities even as they enhance emergency preparedness for

response to possible accidents. Improving the safe use and

management of chemicals begins with an understanding of:

• How and why accidents occur;

• How industry identifies chemical and process hazards; 

• How industry designs, maintains, and operates a safe

facility; and

• How the consequences of accidents are minimized.

Industry has the expertise and responsibility to make sure

that the elements of safe operation (e.g., procedures, training, maintenance) are brought together and managed day-today. Government agencies can help sources by auditing

their safety management programs, comparing them to successful practices used by other sources, and stimulating

improvements. 

The Risk Management Program regulations are among the

several tools implementing agencies have to help facilities

prevent chemical accidents. Existing and new programmatic

tools are briefly described below. Each of these programs is

designed to help identify the causes of accidental chemical

releases as well as the means to prevent them from occurring. Additionally, these activities can be used to promote

coordination within the local community. 

Chemical Safety Audits

Chemical Safety Audits are designed to:

• Share information about chemical safety practices and

technologies with visits to sources that handle hazardous

substances;

• Heighten awareness of the need for and promote chemical safety at chemical facilities and in the communities

where chemicals are located; and

• Build cooperation among sources, government agencies,

and others.

Accident 

prevention 

opportunities

include:

■ Chemical

Safety Audits

■ Accident 

investigation

■ General Duty

■ RMP Audits
5

Introduction

Interrelated Opportunities

for Accident Prevention

Chemical safety audits are usually voluntary and may include

sources not covered by the Risk Management Program provisions. One purpose of auditing a facility is to identify and

characterize the strengths and weaknesses of specific chemical accident prevention program areas, as a means to highlight the elements which form an effective program.

Additionally, audits facilitate the sharing of information

about successful practices and recommending safety improvements. This can lead to process safety improvements, which

may prevent or mitigate releases by the audited source.

Accident Investigations 

The fundamental objective of a chemical accident investigation is to determine the facts, conditions, circumstances, and

causes or probable causes of chemical accidents. The ultimate goal of the accident investigation is to determine the

root causes or management system failures causing an accident in order to reduce the likelihood of recurrence, minimize the consequences associated with accidental releases,

and make chemical production, processing, handling, and

storage safer. Along with the root cause, the investigation

looks at contributing factors of the event that may have

broad applicability to industry, and the potential to develop

recommendations and lessons learned to prevent future accidents of this type. 

Section 112(r)(6) of the Clean Air Act established an independent safety board known as the Chemical Safety and

Hazard Investigation Board ("the Chemical Safety Board").

One of the objectives of the Chemical Safety Board, as directed by the Clean Air Act, is to investigate, determine and

report to the public, the facts, conditions, circumstances, and

cause or probable cause of any accidental release resulting in

fatality, serious injury or substantial property damage. 

The General Duty Clause 

Section 112(r)(1) of the Clean Air Act, known as the

"General Duty Clause," further expands the range of activities EPA can undertake to promote chemical safety. 

Owners and operators of stationary sources producing, processing, handling, or storing extremely hazardous substances

have a general duty to:

• Identify hazards associated with a potential accidental

release, using appropriate hazard assessment techniques;

The Chemical Safety

Board began operating in 1998 after it

was funded by

Congress. EPA and

the Chemical Safety

Board have developed

a Memorandum of

Understanding which

addresses their respective authorities and

coordination on accident investigation. To

view this MOU, see

www.epa.gov/ceppo/

ap-acin.htm. 

For further information

concerning the

Chemical Safety

Board, visit the web

site at 

http://chemsafety.gov

or http://csb.gov.
Guidance for Auditing Risk Management Plans & Programs

6

• Design and maintain a safe facility, taking steps to prevent releases; and

• Minimize the consequences of accidental releases that

do occur. 

The General Duty Clause is not limited to a finite list of

chemicals or established thresholds. 

To the extent state or local law establishes a similar general

duty, implementing agencies other than EPA can take

actions to promote safe operating practices and the prevention of chemical accidents.

RMP Audits

RMP audits help ensure compliance with the Risk

Management Program. EPA intends to use the audit

process as a way to verify the quality of the program summarized in the RMP. When it is reasonable, EPA will

require modifications to the RMP that may lead to quality

improvements in the underlying program. 

Each government agency, whether federal, state, or local,

should determine what authorities it presently has to conduct the above activities. Most should find that their present authorities are sufficient. The agency should consult

with legal counsel to determine the most effective use of

their authorities.

The above-mentioned activities are not mutually exclusive.

Many times, a combination of activities may be used to

achieve results. For example, an agency might investigate a

chemical accident at a facility. While the investigation may

determine a root cause, a chemical safety audit may confirm that procedures are being used to reduce the risk of

future accidents. Additionally, the agency may also audit

compliance with the General Duty Clause and/or RMP

requirements. 
7

Who is Covered?

EPA estimates that approximately

36,000 facilities are covered by the

provisions of 40 CFR Part 68, including: 

Chemical manufacturers (industrial

organics and inorganics, paints, pharmaceuticals, adhesives, sealants, fibers), 

Petrochemical (refining and gas processing operations, plastics and resins,

synthetic rubber), 

Other manufacturing (electronics,

semiconductors, paper, fabricated metals, industrial machinery, furniture, textiles), 

Agriculture (fertilizers), 

Public sources (drinking and waste

water treatment works), 

Electric utilities, 

Food and cold storage, 

Chemical warehousing, 

Chemical wholesalers, 

Military and energy installations,

and 

Other stationary sources. 

RISK MANAGEMENT PROGRAM REQUIREMENTS

Section 112(r) of the CAA requires EPA to publish rules and

guidance for chemical accident prevention. The rules promulgating the list of regulated substances (published January

31, 1994) and the Risk Management Program provisions

(published June 20, 1996) are found at 40 CFR Part 68. The

Risk Management Program contains three elements: a hazard assessment, a prevention program, and an emergency

response program. The entire program is to be described

and documented in a risk management plan (RMP) which is

submitted to EPA. 

In general, the RMP submitted by most facilities includes the

following:

• Executive summary;

• Registration information;

• Off-site consequence analysis;

• Five-year accident history;

• Prevention program; and

• Emergency response program

Owners or operators of a stationary source with more than a

threshold quantity of a regulated substance (one of the 140

listed toxic and flammable substances in 40 CFR Section

68.130) in a process, as determined under section 68.115,

must submit an RMP no later than the latest of the following

dates:

(1) June 21, 1999;

(2) Three years after the date on which a substance is first

listed under 40 CFR 68.130; or

(3) The date on which a regulated substance is first present

in a process above a threshold quantity.

The Risk Management Program regulations also define the

activities that sources must undertake to identify and minimize the risks posed by regulated substances in covered

processes. Specifically, EPA defined three "program levels" to

ensure that individual chemical processes are subject to

appropriate requirements based on the size of the process

and the associated risks. (see table on next page).

Introduction

Risk Management

Program Requirements
Guidance for Auditing Risk Management Plans & Programs

8

Requirements • Conduct an off-site

consequence analysis

that evaluates worst-case

accidental release scenario(s);

• Document the five-year

history of certain accidental releases of regulated substance from

covered processes;

• Coordinate response

plans with local emergency planning and

response agencies; and

• Revise, update, and

submit the RMP at least

every five years.

• Conduct an off-site

consequence analysis

that evaluates worst-case

accidental release scenario(s);

• Document the five-year

history of certain accidental releases of regulated substance from

covered processes;

• Coordinate response

plans with local emergency planning and

response agencies; and

• Revise, update, and

submit the RMP at least

every five years.

Evaluate alternative accident release scenarios

and establish:

• An integrated prevention program for managing risk;

• Provisions for responding to emergencies; and

• An overall management system supervising

the implementation of

these program elements.

• Conduct an off-site

consequence analysis

that evaluates worst-case

accidental release scenario(s);

• Document the five-year

history of certain accidental releases of regulated substance from

covered processes;

• Coordinate response

plans with local emergency planning and

response agencies; and

• Revise, update, and

submit the RMP at least

every five years.

Evaluate alternative accident release scenarios

and establish:

• An integrated prevention program for managing risk;

• Provisions for responding to emergencies; and

• An overall management system supervising

the implementation of

these program elements.

Program Level

Description

Program 1

Requirements apply to

processes where (1) a

worst- case release, as

determined by the hazard assessment, is not

expected to reach public

receptors; (2) no accidental release has

occurred in the last five

years that caused specified off-site impacts; and

(3) the source has coordinated emergency

response procedures

with the local planning

and response organizations. The most likely

processes for this program level are those at

remotely located sources

and/or those using listed flammable chemicals.

Program 2

Requirements apply to

processes that do not

meet the eligibility

requirements of

Program 1 or 3.

Program 3

Requirements apply to

processes not eligibile

for Program 1, and

which are in certain

specified industrial categories or are already

subject to the OSHA

process safety management (PSM) standard.

These generally include

higher risk, complex

chemical processing and

petroleum refining operations.

TABLE 1: RMP PROGRAM LEVELS AND REQUIREMENTS
9

Introduction

Developing an 

RMP Program

RMP audits focus

on compliance

with the plan

requirements, as

well as the

underlying risk

management

program

DEVELOPING AN RMP AUDIT PROGRAM

Objective

The RMP regulation states that, in addition to inspections for

the purpose of regulatory development and enforcement of

the CAA, the implementing agency shall periodically audit

RMPs to review their adequacy and require revisions when

necessary to ensure compliance with the Risk Management

Program regulations. This means that the implementing

agency is responsible for verifying RMP information against

an independent source of information, such as data from

other EPA or state databases, or by conducting on-site verification. 

RMP audits focus on the data contained in the Risk

Management Plan, as well as the underlying risk management program. An RMP is a blueprint of how Risk

Management Program provisions are incorporated into

process safety at the facility, just as an emergency response

plan is a blueprint of an emergency response program for a

community or a facility. Emergency plans do not directly

protect the public; emergency response programs are the

comprehensive approach to protecting the public.

Approaches to an RMP Audit 

Full compliance with the Risk Management Program regulations cannot be determined without on-site or independent

verification of all or part of the information submitted in an

RMP. However, each implementing agency should determine the scope of the audit process to be used. This determination is based on available resources, priorities, expertise,

and other factors. Auditing to ensure compliance with the

Risk Management Program regulation may consist of a range

of off-site and on-site activities. Off-site activities might

include determining that the rule applies to the source, that

the facility placed itself in the correct program level, and that

the source submitted a complete and correct RMP. On-site

activities might include verification of documentation and

process review.

To ease the inspection burden, the implementing agency

should also determine how the scope and conduct of on-site

audit activities can be coordinated with other regulatory

inspections. For example, the implementing agency might

coordinate with either the federal or state OSHA office with-
Guidance for Auditing Risk Management Plans & Programs

10

in its jurisdiction. If chemical facilities are subject to the

OSHA PSM Standard, OSHA has its own authority over the

facilities' prevention program. This inter-agency coordination may save resources and decrease the burden on the

facility. 

How to Use Reviews / Audits / Inspections

The Risk Management Program regulations mention the use

of completeness checks, reviews, audits, and inspections.

These terms are defined below.

RMP Completeness Checks. The implementing agency may

conduct an in-office "completeness check" of the RMP.

RMP*Submit (a submission system developed by EPA) will

check each RMP before it is submitted to ensure that all the

required data elements have been completed; the software

program will indicate which fields are missing any required

information. In addition, the EPA reporting center will use a

similar technique to review every RMP submitted to see if all

necessary fields have been completed.

RMP Reviews. Implementing agencies may want to review

the data in an RMP to identify discrepancies. For example,

the Executive Summary and registration data can be compared to chemical inventory data submitted to the state

under EPCRA section 312 (always remembering that EPCRA

section 312 and CAA section 112(r) may have differences in

thresholds). Agencies may also want to review RMPs to identify internal data inconsistencies (e.g., dates listed for activities should be verified as internally consistent), facilities with

potential problems based on their accident histories, and

unusual data (e.g., failure to list appropriate hazards under

the prevention program). For example, if an RMP reports

that there has recently been a major change in a process that

triggered a review or revision of certain requirements (see

68.170(k)), but the RMP indicates that these requirements

have not been reviewed or revised since the date of the

change, further inquiry is warranted.

RMP Audits. In an audit, the contents of the RMP are

reviewed to determine completeness of the risk management program and adequate compliance with section 112(r)

requirements. Audits involve more than simply reviewing the

RMP; specifically, an audit involves an independent verification of the information in an RMP (e.g., by consulting other

data sources or visiting the facility). Some elements of an

audit include: verifying the number of processes a facility has
11

Introduction

Developing an 

RMP Program

included in its RMP, or the existence of mitigation systems

reported in the RMP. An audit may also focus on accident

histories and off-site consequence analyses (e.g., are the

reported dates reasonable?). Additionally, audits could be

useful in comparing accident histories with accidents reported to the SERC and LEPCs under EPCRA Section 304, which

requires reporting of certain chemical releases. Audits may

also compare practices among facilities within the same

industry sector to determine if particular facilities within the

State are meeting industry standards and implementing

appropriate accident prevention activities. 

Inspections. Inspections complement RMP audit activities

and are valuable for evaluating compliance with the substantive elements of the Section 112(r) rule. Many implementing agencies that have programs for the protection of public

health and safety already have staff who are qualified to conduct on-site inspections (e.g., water permitting agencies visit

water treatment plants; fire inspectors check on propane distributors). With proper training, it may be efficient for these

regulators and inspectors to add 112(r) compliance elements

to their inspection checklist. 

Pursuant to an audit, which may be combined with an inspection, a stationary source may be required to revise its RMP

and correct deficiencies in its underlying program. For

example, if an audit indicated that a stationary source had

not reviewed and updated operating procedures after a

change and that such updates were needed, the stationary

source could be required to update the procedures, re-train

workers in the new procedures, and submit a revised RMP.
Guidance for Auditing Risk Management Plans & Programs

12
13

The RMP Audit Process
Guidance for Auditing Risk Management Plans & Programs

14
15

The RMP Audit Process

Step (I): Selecting Facilities

for RMP Audits

STEP (1): SELECTING FACILITIES FOR RMP AUDITS

Under 68.220(b), the implementing agency may select 

sources for audits based on any of the following criteria:

(1) Accident history; 

(2) Accident history of other sources in the same industry;

(3) Quantity of regulated substances; 

(4) Location and proximity to the public and environmental

receptors;

(5) Presence of specific regulated substances;

(6) Hazards identified in the RMP; or

(7) A plan providing for neutral, random oversight.

Related criteria could include the number of accidental

releases, whether there have been any catastrophic accidental

releases, and the known toxicity of chemicals used in the

processes.

Stationary sources with a "Star" or "Merit" ranking under

OSHA's voluntary protection program are exempt from

audits based solely on criteria (2) and (7). However, these

sources may be audited based on any of the other five criteria [68.220(c)]. Each implementing agency should develop

a targeting system, based on their resources and priorities. 

There are several

basic steps to conducting an RMP audit.

(1) The first is selecting facilities to be

audited. (2) Next,

there is a range of

potential off-site, onsite, and concluding

activities. (3) Finally,

there is a series of

post-audit actions.
Guidance for Auditing Risk Management Plans & Programs

16

STEP (2): OFF-SITE ACTIVITIES

If more than one auditor is participating in the audit, the

entire audit team should participate in a planning meeting

prior to the audit. This meeting should include any personnel from outside the implementing agency who will participate in the audit. The team should include personnel from

the implementing agency and personnel from other agencies

to provide technical support (i.e., fire marshal, emergency

management staff, environmental management staff).

Additionally, if possible, the implementing agency should

include LEPC members and/or local response agency members.

The lead auditor should determine at this point whether or

not the source will be notified in advance of the site visit.

Prior notification may be dictated by implementing agency

policy or practices. If the source is to be notified in advance

of the visit, the lead auditor should schedule well in advance

the date, time, and point of arrival at the source.

The lead auditor should:

• Brief all auditors on the rationale for the audit; 

• Assign each auditor specific section(s) of the audit

report, including collecting stationary source background

information related to his/her report section;

• Identify related regulatory requirements (e.g., hot work

permit, HAZWOPER); and

• Establish a schedule for completing collection of the necessary background information, conducting the pre-visit

meeting, conducting the audit, and completing the audit

report.

Collecting Background Information

Preliminary preparation is key to a well organized audit. It is

useful to collect as much of the source background information as possible in advance of the audit. The lead auditor

may elect to notify the source, state, and local officials of the

pending audit and request appropriate background information. The auditor(s) then can review this information prior

to the visit, prepare a detailed list of topics and questions to

help organize their on-site activities, and minimize the

amount of time spent at the source. The following table lists

some examples of background information that may be useful to auditors.
17

The RMP Audit Process

Step (2): Off-Site Activities

TABLE 2: BACKGROUND INFORMATION

Types of Information Sources of Information

Submitted RMP RMP*Info and/or RMP*Review (database available to the implementing agency from EPA).

History of releases at the source and/or similar sources On-scene coordinator reports, Accidental

Release Investigation Program (ARIP) questionnaires, RMPs, Emergency Response Notification

System (ERNS) data, EPCRA 304 release notifications, State release files.

Chemical processes Industry standards and processing techniques

from trade and professional groups

(e.g.,American Institute of Chemical Engineers

(AIChE), ASME, and the Chlorine Institute),

process flow diagrams, and piping and instrumentation diagrams.

EPCRA Chemical Inventory Data SERC, LEPC, local fire department.

Auditors should also determine the applicability of existing

checklists specific to the source being audited; for example,

checklists developed by EPA in sector-specific RMP guidances

may be used (e.g., ammonia refrigeration, publicly owned

treatment works, chemical warehouses, propane users).

Auditors should also familiarize themselves with industry and

government standards specific to the source (e.g., standards

developed by OSHA, NFPA, ANSI).

Planning the Audit

An on-site audit might include review of programs and

records, verification of data, and analysis of prevention measures. See the following table of potential audit components

for suggestions.

Prepare Audit Staff and Plan Logistics 

The lead auditor should hold a pre-visit meeting with all

auditors as close to the date of the audit as possible. By this

time all auditors should be familiar with this guidance and

any information they have collected about the stationery

source to be audited and its processes. Additional information to be obtained at the source should be identified and

auditors should develop individual plans for conducting their
Guidance for Auditing Risk Management Plans & Programs

18

TABLE 3: POTENTIAL AUDIT COMPONENTS

Review • accident history

• incident investigation reports, and documentation of corrective measures taken

• preventive maintenance program

• process hazard analysis or hazard review, including review of safety information

and risk scenarios

• soundness of air modeling results

• operation and maintenance records, inspection procedures, and repairs records

• training records and review of emergency plan exercise program

• emergency response program capabilities, including exercises, equipment, training, off-site programs, public notification, procedures, and communication with

local emergency responders

• management of change program, pre-start review program, employee participation program, hot work permit program, and contractor employee training

Verify • facility classification and program designation

• air modeling methods and results

• model input parameters

• mitigation measures and systems

• process enhancements, including facility-conducted compliance audit results

and recommendations

Evaluate • additional (unreported) covered processes

Engineering review • processes

Engineering analyses • release prevention measures

Engineering verification • mitigation measures, design parameters

portion of the audit. For extensive audits, the pre-visit meeting should:

• Establish the entry authority of each auditor;

• Review each auditor's area of responsibility;

• Review the audit objectives and highlight areas of special

interest;

• Review any site-specific personal health and safety issues,

and complete, if necessary, a site safety plan for on-site

activities;

• Review information about key personnel and operations

at the site;

• Establish an agenda for each day of the site visit;

• Review logistical matters (e.g., nightly team meetings to

discuss results and plan the next day's activity); 
19

The RMP Audit Process

Step (2): Off-Site Activities

• Review the RMP submitted by the source and preliminarily evaluate compliance with regulatory requirements;

• Arrange for proper management of confidential business

information (CBI); and

• Cover any additional topics.

The lead auditor should also:

• Develop site-specific guidance, if needed;

• Reserve work space and equipment at the source; 

• Develop employee interview questionnaires, if an interview is planned; and

• Schedule opening meetings, closing meetings, and daily

debriefings.
Guidance for Auditing Risk Management Plans & Programs

20

STEP (3): AT THE SITE

Entering the Facility

Under 40 CFR 68.220(d), the implementing agency shall

have access to the source, supporting documentation, and

any area where an accidental release could occur. Upon

entering the source, the auditor(s) should present their official credentials. The auditor(s) should arrive at the source

during normal working hours. The auditor(s) may sign a

"sign-in" sheet, log, or visitor register. However, the

auditor(s) must not sign any type of "waiver" or "visitor

release" which would relieve the source of responsibility for

injury or limit the rights of the auditing agencies to collect or

use data obtained from the stationary source. If a waiver or

release is presented, the lead auditor should explain that

such a document will not be signed and request a blank

"sign-in" sheet. If the auditors are refused entry because they

will not sign a release, the lead auditor should report all pertinent facts to the implementing agency's legal counsel. If

the matter cannot be resolved, the auditor(s) should leave

the facility. All events surrounding the refused entry must

be fully documented, including the name(s) of the person(s)

refusing entry. 

Opening Meeting 

The auditor(s) should conduct an opening meeting with

management personnel (e.g., plant manager, superintendents of safety and operations, legal counsel, corporate representative). The lead auditor should clearly explain the

purpose and objectives of the audit. 

The lead auditor may give a copy of this guidance to the

source to help them understand the scope, purpose, and

objective of the audit. In addition, this guidance may help

the source in assembling information to be reviewed by the

auditor(s). At a minimum, the following items should be

addressed during the opening meeting: 

• Discussion of entry and information gathering authorities

(with presentation of auditor(s) credentials);

• Audit purpose and objectives;

• On-site agenda;

• Identification and management of CBI;

• Information necessary to conduct the audit; 
21

The RMP Audit Process

Step (3): At the Site

• Safety issues (e.g., source-specific safety orientation training, emergency response procedures and alarms that may

sound in an emergency); 

• Schedule for exit briefing; and

• Audit report preparation.

The auditor(s) should also request a detailed overview of the

chemical processes and/or manufacturing operations at the

source, including block flow and/or process flow diagrams

indicating chemicals and processes involved.

Prior to walking around the facility, the auditor(s) should

request an explanation of the source's Risk Management

Program, including, at a minimum:

• How the elements of the program are implemented;

• Personnel who are responsible for the implementation of

the various elements of the program; and

• A description of the source's records documenting compliance.

At the conclusion of the opening meeting, the lead auditor

should request access to the following information, where

applicable:

• Documentation for the hazard assessment, including

selection of model and procedures followed;

• Documentation supporting reports under the five-year

accident history (e.g., follow-up release reports, initial

notifications);

• Documentation for the process hazards analysis or hazard

review;

• Standard operating procedures;

• Training records (e.g., hazard communication, emergency response) for all employees ;

• Pre-startup safety review;

• Integrity or preventive maintenance records;

• Hot work permit program;

• Written procedures to manage change to processes;

• Plan of action for implementation of employee participation;

• Written process safety information;
Guidance for Auditing Risk Management Plans & Programs

22

• Incident investigation reports;

• The emergency response plan developed by the source;

• The two most recent compliance audit reports; and

• Documentation on coordination with local officials on

emergency response activities

Collecting and Analyzing Information

After the opening meeting, the auditor(s) may accomplish

their tasks individually or in small groups, performing their

work as quickly and efficiently as possible. Special attention

should be paid to: 

• Verifying the reported program level; and

• Comparing the stationary source's RMP to policies and

procedures actually implemented, especially for production or equipment changes.

The attached checklist may be used as guidance to ensure

that regulatory requirements are met and that a basic level of

data quality is achieved. However, this checklist is not intended to be comprehensive of all applicable requirements.

Accordingly, the checklist is not a substitute for knowledge

and understanding of the regulations.

During the audit, a variety of materials will be gathered relating to operations at the source. Most of these materials

should be referenced in the report and maintained in a central file. 

Examples of the types of material that might be included are:

• Sample source memoranda, guidelines, safe operating

procedures, policy statements (e.g., safety practices,

Responsible CARE);

• Correspondence between the source and the implementing agency; or

• Graphic materials such as photographs, maps, charts, plot

plans, organizational charts.

All materials should be labeled with :

• Name of the source;

• Date of the audit; and

• Other identifying information.

Confidential Business

Information

During the course of

the audit, auditor(s)

may have access or

obtain information that

may be entitled to confidential treatment. It

is the source's responsibility to identify this

information as

Confidential Business

Information (CBI) to

the auditor(s), in

accordance with the

Risk Management

Program regulations.

This information will

be handled in accordance with the implementing agency's procedures (e.g., 40 CFR

Part 2 for EPA personnel). Before visiting

the site, auditor(s)

should check to see if

their agency has training or programs on

handling CBI.
The RMP Audit Process

Step (3): At the Site

Personal Protective Equipment (PPE)

In addition to normal protective equipment (e.g., safety

shoes, hard hats, goggles), auditor(s) may need special

equipment: 

• Flame-retardant coveralls in all areas of the plant where

there is potential for flash fires and as may be required by

policy at the source;

• Emergency escape respirators during the walk-around

portion of the audit (personnel conducting these audits

should have received proper training in the use of emergency escape respirators);

• Alert monitors approved for the environment where they

will be used (e.g., HCN, Cl2);

• Electronic equipment (i.e., still cameras, video cameras,

cellular phones) that are safe for use in the process areas

being audited; and 

• Follow facility guidance relative to the appropriate use of

PPE and request notice of any unusual conditions which

may dictate specific precautions.

Exit Briefing

Prior to the exit briefing, auditor(s) should meet privately to

review findings and establish topics for the briefing.

Significant observations and findings should be presented to

management personnel. Any issues requiring clarification

should be listed for discussion with the management personnel. The team leader will determine what conclusions or recommendations will be forwarded to the source at the exit

briefing.

In the exit briefing, the auditor(s) will meet with the management personnel to discuss the audit results. The lead

auditor should report to the source management all significant findings, conclusions, and recommendations for which a

team consensus exists. 

Auditor(s) should maintain a professional, courteous

demeanor during all discussions with source personnel.

Auditor(s) should make source officials aware of any standards, guidelines, or resources that would be helpful in

improving the source risk management program. However,

auditor(s) should be careful to avoid making suggestions

which imply a "consultant" type of relationship, such as

endorsing one product or firm exclusively. 

Exit Briefing

• Maintain a 

professional courteous

demeanor;

• Make source officials

aware of helpful 

standards, guidelines,

or resources;

• Alert management to

situations requiring

immediate remediation

• Avoid implying a

“consulting” relationship

• Do not state that 

violations have been

observed

• Avoid statements that

affect subsequent

enforcement actions

23
Guidance for Auditing Risk Management Plans & Programs

24

Auditor(s) should never state that "violations" have been

observed. Determining that a violation has occurred is generally done after an enforcement inspection by the appropriate enforcement program in consultation with legal counsel.

Auditor(s) should not make any representations that could

affect any subsequent enforcement actions against the source

(e.g., guaranteeing no enforcement will be taken if a source

performs certain actions to correct a deficiency).

The audit leader should alert the management personnel to

situations that are in need of immediate remediation (e.g.,

improper storage of incompatible chemicals).
25

The RMP Audit Process

Step (4): Concluding

Activities

STEP (4): CONCLUDING ACTIVITIES

Follow-up Meeting

Auditor(s) should meet as soon as possible after completion

of the site visit to ensure details of the audit are accurately

recorded. At a minimum, auditor(s) should:

• Immediately review and edit personal notes taken during

the site visit for clarity and completeness;

• Review report format, and identify any additional information needed to complete the report;

• Review all important observations and findings;

• Agree on a date for the final report;

• Differentiate recommendations from any observed noncompliance; and 

• Resolve conclusions or recommendations that are not

supported by team consensus.

Audit Report

The report should summarize information gathered during

the audit (the attached checklists may be helpful). The

report should include:

• A basic profile of the source and general information

about the audit;

• A description of the criteria, rationale, and factual information used to select the source for an audit; and

• Findings, conclusions, and recommendations. 

The findings, conclusions, and recommendations section

should summarize the rest of the information from the completed checklists. Each finding should be documented with

information collected through document reviews. The auditor(s) should not interject opinions or speculative statements

in findings. Any conclusions should be based upon a comparative analysis of the finding with applicable rules, regulations, standards, and accepted guidances. Conclusions

should be accompanied by recommendations. Each recommendation should cite the specific rules, regulations, standards, accepted guidances, or technical basis used to formulate the recommendation. The lead auditor should consult

with all appropriate auditors and personnel in the implementing agency to determine if recommendations that are

not supported by a team consensus should be included.
Guidance for Auditing Risk Management Plans & Programs

26

Each auditor should sign the report before it is submitted to

the appropriate agencies. The original report should be

maintained by the implementing agency. A copy of the

report should be forwarded to the facility's owner or operator, as well as to the: 

• State Emergency Response Commission;

• Local emergency planning committee in whose area the

stationary source is located; and

• If requested, any other federal, state, and local agencies

that participated in the audit.
27

The RMP Audit Process

Step (5): After-Audit

Actions

STEP (5): AFTER-AUDIT ACTIONS

Preliminary Determination

Based on the results of the audit, the implementing agency

may issue the owner or operator a written preliminary determination of necessary revisions to the stationary source's

RMP to ensure that the RMP meets the criteria of 40 CFR

Part 68, Subpart G. The preliminary determination should

include an explanation of the basis for the revisions, reflecting industry standards and guidelines (such as American

Institute of Chemical Engineers (AIChE)/The Center for

Chemical Process Safety (CCPS) guidelines and American

Society of Mechanical Engineers (ASME) and American

Petroleum Institute (API) standards), to the extent that such

standards and guidelines are applicable. The preliminary

determination should also include a timetable for the implementation of the revisions [68.220(e)].

The owner or operator should respond in writing to the preliminary determination. The response should state that the

owner or operator will implement the revisions contained in

the preliminary determination in accordance with the

timetable included in the preliminary determination, or

should state that the owner or operator rejects the revisions

in whole or in part. For each rejected revision, the owner or

operator should explain the basis for rejecting that revision.

Such explanation may include substitute revisions

[68.220(f)(1)].

The written response should be received by the implementing agency within 90 days of the issuance of the preliminary

determination. The implementing agency may specify a

shorter period of time in the preliminary determination to

protect public health and the environment. Prior to the written response being due and upon written request from the

owner or operator, the implementing agency may provide

additional time for the response to be received

[68.220(f)(2)].

Final Determination

After providing the owner or operator an opportunity to

respond to the preliminary determination, the implementing

agency may issue the owner or operator a written final determination of necessary revisions to the stationary source's

RMP. The final determination may adopt or modify the revisions contained in the preliminary determination, or may

adopt or modify the substitute revisions provided in response
Guidance for Auditing Risk Management Plans & Programs

28

to the preliminary determination. A final determination that

adopts a revision rejected by the owner or operator should

include an explanation of the basis for the revision. A final

determination that fails to adopt a substitute revision provided under 68.220(f) should include an explanation of the

basis for finding such substitute revision unreasonable

[68.220(g)].

Thirty days after completion of the actions detailed in the

implementation schedule set in the final determination, the

owner or operator will be in violation of subpart G of part 68

unless the owner or operator revises the RMP, as required by

the final determination, and submits the revised RMP

[68.220(h)].

Once a final determination has been made and the stationary source is deemed to be in violation of 40 CFR Part 68, the

audit report along with the final determination should be

referred to the appropriate program within the implementing agency for enforcement actions. If warranted, the implementing agency may initiate an enforcement action, rather

than use the preliminary and final determination process.

The public should have access to the preliminary determinations, responses, and final determination pursuant to 42

U.S.C. 7414(c) [68.210(a),68.220(i)]. The disclosure of classified information by the Department of Defense or other

federal agencies or contractors of such agencies will be controlled by applicable laws, regulations, or executive orders

concerning the release of classified information [68.210(b)].

None of the actions described above will preclude, limit, or

interfere in any way with the authority of the implementing

agency to exercise its enforcement, investigatory, and information gathering authorities under the CAA concerning

accidental releases [68.220(j)].
29

Annexes
Guidance for Auditing Risk Management Plans & Programs

30
ANNEX A: SITE SAFETY PLAN FOR ON-SITE ACTIVITIES

A-1

A

Site Safety Plan

The EPA Safety Manual, Chapter 9, and other EPA Policies articulate certain safety

planning efforts prior to field activities. The following format is consistent with these

requirements. Extensive training and certifications, and further planning in the form of

a more extensive Site Safety Plan, may be necessary in addition to the following plan.

STATIONARY SOURCE

LEAD AUDITOR

DATE

DESCRIPTION OF ACTIVITIES

Location and approximate size of stationary source:

Description of tasks and activities to be performed by each of the auditors:

Proposed date of on-site activities beginning:

Duration of the planned activities:

Site topography:

Site accessibility by roads and air:
Guidance for Auditing Risk Management Plans & Programs

A-2

HAZARDOUS SUBSTANCES AND HEALTH HAZARDS INVOLVED OR SUSPECTED

AT THE SITE (Fill in any information that is known or suspected)

Areas of Concern Chemical and Physical Identity of Substance 

Properties and Precautions

Explosivity

Radioactivity

Oxygen deficiency

(e.g., confined spaces)

Toxic gases

Skin / eye contact

hazards

Heat stress

Pathways from site for hazardous substances dispersion:

WORK PLAN INSTRUCTIONS

Recommended level of protection:

❏A

❏B

❏C

Cartridge type if level C:
A-3

A

Site Safety Plan

Monitoring equipment to be used:

Accompanying/helping persons (stationary source/contractors):

Safety clothing/equipment required for those persons:

OSHA required training and certification (29 CFR 1910.120) received by 

those persons:

FIELD INVESTIGATION AND DECONTAMINATION PROCEDURES

Decontamination procedures (contaminated protective clothing, instruments, 

equipment, etc.):

Disposal procedures (contaminated equipment, supplies, disposable items, 

washwater, etc.):
Guidance for Auditing Risk Management Plans & Programs

A-4

EMERGENCY CONTACTS

Hospital Phone No.: ____________________________________________

Fax: _____________________________________________________________

Emergency Medical Treatment Phone No.: _____________________

Fax: _____________________________________________________________

Ambulance Phone No.: _________________________________________

Fax: _____________________________________________________________

Hospital Location:

Police Phone No.: _______________________________________________

Fire Assistance Phone No.: _____________________________________

Regional Health and Safety Officer 

(or position with similar duties): ________________________________

Phone: __________________________________________________________

NOTES
B-1

B

Audit Report

ANNEX B: AUDIT REPORT

Note: A report similar to this will be generated by RMP*Review, the software available to RMP implementing agencies.

EPA facility ID #:

City: _____________________________ State: __________ County: ______________________

Date:

AUDIT TEAM:

Lead Auditor:

Auditors:

Date(s) of stationary source visit:

I. STATIONARY SOURCE IDENTIFICATION

Name:

Street Address:

City: _____________________________ County: ______________________ State: __________

Zip: ______________________

Latitude:

Longitude:
Guidance for Auditing Risk Management Plans & Programs

B-2

Dun & Bradstreet No.: _____________________________

Name, address, and D & B of corporate parent company (if applicable):

Owner / operator: __________________________________________ Phone: __________________

Mailing Address:

City:__________________________ State: ________________________ Zip: ____________________

Name, title, and phone of person responsible for 40 CFR Part 68 implementation:

Name: ______________________ Title: __________________________ Phone: __________________

Name and title of emergency contact:

Day Phone: __________________ 24-hour Phone: ________________________________________

Names, titles, and phones of stationary source personnel involved in audit (accompanied site tours, provided documents and explanations, etc):

II. DATE AND PROGRAM LEVELS OF SUBMITTED RMP

Date of Initial Submission: ___ ___ / ___ ___ / ___ ___ 

Date of Latest Update: ___ ___ / ___ ___ / ___ ___

Process (Program 1, 2, 3) as reported in RMP:

Process ID#: Program Level: NAICS Code:
B-3

B

Audit Report

III. FINDINGS, CONCLUSIONS, AND RECOMENDATIONS*

Signatures: __________________ Lead Auditor: __________________________________________

Auditors: ________________________________________________

Approved by:

Signature: __________________________________________________ Date:____________________

Title: ____________________________________________________________________________________

* Findings, conclusions, and recommendations may be presented in one or 

several attachments and referred to in the report.
Guidance for Auditing Risk Management Plans & Programs

B-4
C

Audit Checklist

C-1

ANNEX C: AUDIT CHECKLIST

Process audited: 

Auditor: 

Instructions: This checklist may be used for verification of RMP and Program compliance

(Check boxes coding: Y=Yes, N=No, P=Partial, A=Not Applicable)

Note: Compliance Objectives appear in the order they appear in the RMP rule

COMPLIANCE OBJECTIVES NOTES

1. RISK MANAGEMENT PROGRAM AND PLAN

(SUBPART A)

Applicability [68.1]

ì

1.1. Does the owner or operator of the stationary source have

more than a threshold quantity of a regulated substance in a

process? [68.10(a)]

ì

1.2. Has the process had, in the five years prior to submission of

the RMP, an accidental release of a regulated substance

where exposure to the substance, its reaction products,

overpressure generated by an explosion involving the

substance, or radiant heat generated by a fire involving the

substance led to any of the following off-site: 

(i) Death; (ii) Injury; or (iii) Response or restoration

activities for an exposure of an environmental receptor?

[68.10(b)(1)]

ì

1.3. Is the distance to a toxic or flammable endpoint for a

worst-case release assessment less than the distance to any

public receptor? [68.10(b)(2)]

ì

1.4. Has the owner or operator coordinated emergency response

procedures between the stationary source and local

emergency planning and response organizations?

[68.10(b)(3)]

ì

1.5. Is the covered process subject to OSHA PSM standard, 29

CFR 1910.119? [68.10(d)(2)]

ì

1.6. Is the covered process in one of the NAICS codes listed in

40 CFR §68.10(d)(1)? [68.10(d)(1)]

Auditor may need to re-answer 1.5 and 1.6 for multiple processes in

comments section.
Guidance for Auditing Risk Management Plans & Programs

COMPLIANCE OBJECTIVES NOTES

C-2

General Requirements [68.12]

ì

1.7. Has the owner or operator submitted a single RMP, which

included a registration that reflects all covered processes, as

provided in 68.150 to 68.185? [68.12(a)]

1.8. For Program 1 processes audited, has the owner or operator:

[68.12(b)]

ì

1.8.1. Analyzed the worst-case release scenario for the process(es), as

provided in 68.25; [68.12(b)(1)]

ì

1.8.2. Documented that the nearest public receptors is beyond the

distance to an endpoint defined in 68.22(a); and [68.12(b)(1)]

ì

1.8.3. Included the scenario(s) in the RMP as provided in 68.165?

[68.12(b)(1)]

ì

1.8.4. Completed the five-year accident history for the process as

provided in 68.42 [68.12(b)(2)]; and

ì

1.8.5. Included the history in the RMP as provided in 68.168?

[68.12(b)(2)]

ì

1.8.6. Ensured that response actions have been coordinated with local

emergency planning and response agencies? [68.12(b)(3)]

ì

1.8.7. Included the appropriate certification statement for Program 1

processes? [68.12(b)(4)]

1.9. For Program 2 processes, has the owner or operator: [68.12(c)]

ì

1.9.1. Developed and implemented a management system as

provided in 68.15? [68.12(c)(1)]

ì

1.9.2. Conducted a hazard assessment as provided in 68.20 through

68.42? [68.12(c)(2)]

ì

1.9.3. Implemented the Program 2 prevention steps provided in 68.48

through 68.60 or implemented the Program 3 prevention steps

provided in 68.65 through 68.87? [68.12(c)(3)]

ì

1.9.4. Developed and implemented an emergency response program

as provided in 68.90 to 68.95? [68.12(c)(4)]

ì

1.9.5. Submitted, as part of the RMP, the data on prevention program

elements for Program 2 processes as provided in 68.170?

[68.12(c)(5)]
C

Audit Checklist

COMPLIANCE OBJECTIVES NOTES

C-3

1.10. For Program 3 processes, has the owner or operator: [68.12(d)]

ì

1.10.1. Developed and implemented a management system as

provided in 68.15? [68.12(d)(1)]

ì

1.10.2. Conducted a hazard assessment as provided in 68.20 through

68.42? [68.12(d)(2)]

ì

1.10.3. Implemented the prevention requirements provided in 68.65

through 68.87? [68.12(d)(3)]

ì

1.10.4. Developed and implemented an emergency response program

as provided in 68.90 to 68.95? [68.12(d)(4)]

ì

1.10.5. Submitted, as part of the RMP, the data on prevention program

elements for Program 3 processes as provided in 68.175?

[68.12(d)(5)]

Management [68.15]

Has the owner or operator:

ì

1.11. Developed a management system to oversee the

implementation of the risk management program elements?

[68.15(a)]

ì

1.12. Assigned a qualified person or position that has the overall

responsibility for the development, implementation, and

integration of the risk management program elements?

[68.15(b)]

ì

1.13. Documented other persons responsible for implementing

individual requirements of the risk management program and

defined the lines of authority through an organization chart or

similar document? [68.15(c)]

General Findings / Conclusions:
Guidance for Auditing Risk Management Plans & Programs

COMPLIANCE OBJECTIVES NOTES

C-4

Documentation obtained to support Findings / Conclusions:

2. RMP SUBMISSION (SUBPART G) 68.150 - 68.190

ì

2.1. Did the owner or operator submit an RMP on or before June

21, 1999? Postmark date of initial submission: [68.10,

68.10(a)(1), 68.150(a) & (b)]

If submission was after June 21, 1999, was submittal required because:

[68.10 & 68.150(b)]

ì

2.1.1. Initial listing of a regulated substance under 68.130 after June

21, 1999 [68.10(a)(2) & 68.150(b)(2)]

ì

2.1.2. A regulated substance was first present at the stationary source

above the threshold quantity in a process [68.10(a)(3) &

68.150(b)(2)]

ì

2.2. Has the owner or operator revised and updated the RMP within

5 years of initial submission? Date of the last revision and

update [68.190(a)]: 

2.3. If required, has the owner or operator submitted a revised RMP

for any of the following: [68.190(b)]

ì

2.3.1. Within 3 years after EPA first listed a newly regulated

substance? [68.190(b)(2)]

ì

2.3.2. No later than the date on which a new regulated substance is

first present in an already covered process above a threshold

quantity? [68.190(b)(3)]

ì

2.3.3. No later than the date on which a regulated substance is first

present above a threshold quantity in a new process?

[68.190(b)(4)]

ì

2.3.4. Within six months of a change that requires a revised PHA or

hazard review? [68.190(b)(5)]
C

Audit Checklist

COMPLIANCE OBJECTIVES NOTES

C-5

ì

2.3.5. Within six months of a change that requires a revised off-site

consequence analysis as provided in 68.36? [68.190(b)(6)]

ì

2.3.6. Within six months of a change that alters the Program level

that applied to any covered process? [68.190(b)(7)]

ì

2.4. Has the owner or operator included information submitted as

CBI in the RMP? [68.150(d)]

ì

2.4.1. If so, were the provisions of 68.151 and 68.152 followed ?

RMP: Executive Summary

2.5. Has the owner or operator included a brief description of the

following elements in the executive summary of the RMP:

[68.155]

ì

2.5.1. The accidental release prevention and emergency response

policies at the stationary source? [68.155(a)]

ì

2.5.2. The stationary source and regulated substances handled?

[68.155(b)]

ì

2.5.4. The worst-case release and alternative release scenario(s),

including administrative controls and mitigation measures to

limit the distances for each reported scenario? [68.155(c)]

ì

2.5.5. The general accidental release prevention program and

chemical-specific prevention steps? [68.155(d)]

ì

2.5.6. The five-year accident history? [68.155(e)]

ì

2.5.7. The emergency response program? [68.155(f)]

ì

2.5.8. Planned changes to improve safety? [68.155(g)]
Guidance for Auditing Risk Management Plans & Programs

COMPLIANCE OBJECTIVES NOTES

C-6

RMP: Registration

ì

2.6. Has the owner or operator included a single registration form

in the RMP which covers all regulated substances handled in

covered processes? [68.160(a)]

2.7. Does the registration include the following data: [68.160(b)]

ì

2.7.1. Stationary source name, full address, Dun and Bradstreet

number; longitude and latitude with method and description?

[68.160(b)(1) & (2)]

ì

2.7.2. Corporate parent company name and Dun and Bradstreet

number? [68.160(b)(3)]

ì

2.7.3. The name, telephone number, and mailing address of the

owner or operator? [68.160(b)(4)]

ì

2.7.4. The name and title of the person or position with overall

responsibility for RMP elements and implementation?

[68.160(b)(5)]

ì

2.7.5. The name, title, telephone number, and 24-hour number of the

emergency contact? [68.160(b)(6)]

ì

2.7.6. For each covered process, the name and CAS number of each

regulated substance held above the threshold quantity in the

process, the maximum quantity of each regulated substance or

mixture in the process, the NAICS code, and the Program level

of the process? [68.160(b)(7)]

ì

2.7.7. The stationary source EPA identifier? [68.160(b)(8)]

ì

2.7.8. The number of full-time employees at the stationary source?

[68.160(b)(9)]

ì

2.7.9. Whether the stationary source is subject of 29 CFR §1910.119,

OSHA’s Process Safety Management Standard?

[68.160(b)(10)]

ì

2.7.10. Whether the stationary source is subject to 40 CFR Part 355,

the Emergency Planning Requirements of the Emergency

Planning and Community Right-to-Know Act? [68.160(b)(11)]

ì

2.7.11. If the stationary source has a CAA Title V operating permit, its

permit number? [68.160(b)(12)]
C

Audit Checklist

COMPLIANCE OBJECTIVES NOTES

C-7

ì

2.7.12. The date of the last safety inspection of the stationary source

by a Federal, state, or local government agency and the identity

of the inspecting entity? [68.160(b)(13)]

RMP: Off-site Consequence Analysis

2.8. Does the RMP include the following: [68.165(a)]

ì

2.8.1. One worst-case release scenario for each Program 1 process?

[68.165(a)(1)]

ì

2.8.2. For Program 2 and 3 processes, one worst-case release scenario

to represent all regulated toxic substances held above the

threshold quantity and one worst-case release scenario to

represent all regulated flammable substances held above the

threshold quantity? [68.165(a)(2)]

ì

2.8.3. For Program 2 and 3 processes, were additional worst-case

scenarios also submitted, if required by 68.25(a)(2)(iii)? 

[68.165(a)(2)]

ì

2.8.4. For Program 2 and 3 processes, was information submitted on

one alternative scenario for each regulated toxic substance held

above the threshold quantity and one alternative scenario to

represent all regulated flammable substances held above the

threshold? [68.165(a)(2)]

2.9 Does the RMP include the following information for each

submitted release scenario: [68.165(b)]

ì

2.9.1. Scenario type (explosion, fire, toxic gas release, or liquid spill

and vaporization)? [68.165(b)(5)]

ì

2.9.2. Chemical name of released substance? [68.165(b)(1)]

ì

2.9.3. Percentage weight of the chemical in a liquid mixture (toxics

only)? [68.165(b)(2)]

ì

2.9.4. Physical state of substance (toxics only)? [68.165(b)(3)]

ì

2.9.5. Basis of results (model name if used)? [68.165(b)(4)]
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ì

2.9.6. Quantity released in pounds? [68.165(b)(6)]

ì

2.9.7. Release rate? [68.165(b)(7)]

ì

2.9.8. Release duration? [68.165(b)(8)]

ì

2.9.9. Wind speed and atmospheric stability class (toxics only)?

[68.165(b)(9)]

ì

2.9.10. Topography (toxics only)? [68.165(b)(10)]

ì

2.9.11. Distance to endpoint? [68.165(b)(11)]

ì

2.9.12. Public and environmental receptors within the distance?

[68.165(b)(12)]

ì

2.9.13. Passive mitigation considered? [68.165(b)(13)]

ì

2.9.14. Active mitigation considered (alternative releases scenarios

only)? [68.165(b)(14)]

RMP: Five-year accident history

ì

2.10. Has the owner or operator provided the five-year accident

history information in 68.42 on each accident covered by

68.42? [68.168]

2.11. Does the RMP include the following information for each

reported accidental release: [68.42(b)]

ì

2.11.1. Date, time, and approximate duration of the release?

[68.42(b)(1)]

ì

2.11.2. Chemical(s) released? [68.42(b)(2)]

ì

2.11.3. Estimated quantity released in pounds and percentage weight

in a mixture (toxics)? [68.42(b)(3)]

ì

2.11.4. NAIES code for the process? [68.42(b)(4)]
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ì

2.11.5. The type of release event and its source? [68.42(b)(5)]

ì

2.11.6. Weather conditions (if known)? [68.42(b)(6)]

ì

2.11.7. On-site impacts? [68.42(b)(7)]

ì

2.11.8. Known offsite impacts? [68.42(b)(8)]

ì

2.11.9. Initiating event and contributing factors (if known)?

[68.42(b)(9)]

ì

2.11.10. Whether offsite responders were notified (if known)?

[68.42(b)(10)]

ì

2.11.11. Operational or process changes that resulted from investigation

of the release? [68.42(b)(11)]

RMP: Prevention program / Program 2 [68.17]

2.12. Has the owner or operator included the following information

for each covered process in Program 2? [68.170(a)]

ì

2.12.1. The NAICS code for the process? [68.170(b)]

ì

2.12.2. The name(s) of the chemical(s) covered? [68.170(c)]

ì

2.12.3. The date of the most recent review or revision of the safety

information and a list of Federal or state regulations or

industry-specific design codes and standards used to

demonstrate compliance with the safety information

requirement. [68.170(d)]

ì

2.12.4. The date of completion of the most recent hazard review or

update? [68.170(e)]

ì

2.12.4.1. The expected date of completion of any changes resulting from

the hazard review or update? [68.170(e)(1)]
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ì

2.12.4.2. Major hazards identified? [68.170(e)(2)]

ì

2.12.4.3. Process controls in use? [68.170(e)(3)]

ì

2.12.4.4. Mitigation systems in use? [68.170(e)(4)]

ì

2.12.4.5. Monitoring and detection systems in use? [68.170(e)(5)]

ì

2.12.4.6. Changes since the last hazard review? [68.170(e)(6)]

ì

2.12.5. The date of the most recent review or revision of operating

procedures? [68.170(f)]

ì

2.12.6. The date of the most recent review or revision of training

programs? [68.170(g)]

ì

2.12.6.1 The type of training provided--classroom, classroom plus on

the job, on the job? [68.170(g)(1)]

ì

2.12.6.2. The type of competency testing used? [68.170(g)(2)]

ì

2.12.7. The date of the most recent review or revision of maintenance

procedures and the date of the most recent equipment

inspection or test and the equipment inspected or tested?

[68.170(h)]

ì

2.12.8. The date of the most recent compliance audit and the expected

date of completion of any changes resulting from the

compliance audit? [68.170(i)]

ì

2.12.9. The date of the most recent incident investigation and the

expected date of completion of any changes resulting from the

investigation? [68.170(j)]

ì

2.12.10. The date of the most recent change that triggered a review or

revision of safety information, hazard review, operating or

maintenance procedures, or training? [68.170(k)]

RMP: Prevention program / Program 3 [68.175]

2.13. Has the owner or operator included in the RMP information

addressing 68.175(b) to 68.175(p)? [68.175(a)]
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ì

2.13.1. The NAICS code for the process? [68.175(b)]

ì

2.13.2. The name(s) of the substance(s) covered? [68.175(c)]

ì

2.13.3. The date on which the safety information was last reviewed or

revised? [68.175(d)]

ì

2.13.4. The date of completion of the most recent process hazard

analysis (PHA) or update and the technique used? [68.175(e)]

ì

2.13.4.1. The expected date of completion of any changes resulting from

the PHA? [68.175(e)(1)]

ì

2.13.4.2. Major hazards identified? [68.175(e)(2)]

ì

2.13.4.3. Process controls in use? [68.175(e)(3)]

ì

2.13.4.4. Mitigation systems in use? [68.175(e)(4)]

ì

2.13.4.5. Monitoring and detection systems in use? [68.175(e)(5)]

ì

2.13.4.6. Changes since the last PHA? [68.175(e)(6)]

ì

2.13.5. The date of the most recent review or revision of operating

procedures? [68.175(f)]

ì

2.13.6. The date of the most recent review or revision of training

programs? [68.175(g)]

ì

2.13.6.1. The type of training provided--classroom, classroom plus on

the job, on the job? [68.175(g)(1)]

ì

2.13.6.2. The type of competency testing used? [68.175(g)(2)]

ì

2.13.7. The date of the most recent review of revision of maintenance

procedures and the date of the most recent equipment

inspection or test and the equipment inspected of tested?

[68.175(h)]
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ì

2.13.8. The date of the most recent change that triggered management

of change procedures and the date of the most recent review or

revision of management of change procedures? [68.175(i)]

ì

2.13.9. The date of the most recent pre-startup review? [68.175(j)]

ì

2.13.10. The date of the most recent compliance audit and the expected

date of completion of any changes resulting from the

compliance audit? [68.175(k)]

ì

2.13.11. The date of the most recent incident investigation and the

expected date of completion of any changes resulting from the

investigation? [68.175(l)]

ì

2.13.12. The date of the most recent review or revision of employee

participation plans? [68.175(m)]

ì

2.13.13. The date of the most recent review or revision of hot work

permit procedures? [68.175(n)]

ì

2.13.14. The date of the most recent review or revision of contractor

safety procedures? [68.175(o)]

ì

2.13.15. The date of the most recent evaluation of contractor safety

performance? [68.175(p)]

RMP: Emergency Response Program [68.18]

2.14. Has the owner or operator included the following information

in the RMP on the emergency response program: [68.18]

ì

2.14.1. Does a written emergency response plan exist? [68.180(a)(1)]

ì

2.14.2. Does the plan include specific actions to be taken in response

to an accidental releases of a regulated substance?

[68.180(a)(2)]

ì

2.14.3. Does the plan include procedures for informing the public and

local agencies responsible for responding to accidental

releases? [68.180(a)(3)]

ì

2.14.4. Does the plan include information on emergency health care?

[68.180(a)(4)]

ì

2.14.5. Date of the most recent review of update of emergency

response plan? [68.180(a)(5)]
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C-13

ì

2.14.6. Date of the most recent emergency response training for

employees? [68.180(a)(6)]

ì

2.15. Has the owner or operator provided the name and telephone

number of the local agency with which emergency response

activities and the emergency response plan is coordinated?

[68.180(b)]

ì

2.16. Has the owner or operator listed other Federal or state

emergency plan requirements to which the stationary source is

subject? [68.180(c)]

RMP: Certification [68.185]

2.17. Has the owner or operator: [68.185]

ì

2.18. For Program 1 processes, submitted the certification statement

in 68.12(b)(4)? [68.185(a)]

ì

2.19. For Program 2 or 3 processes, submitted the appropriate

certification statement that to the best of the signer’s

knowledge, information, and belief formed after reasonable

inquiry, the information submitted is true, accurate, and

complete? [68.185(b)]

General Findings / Conclusions:

Documentation obtained to support Findings / Conclusions:
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3. HAZARD ASSESSMENT (SUBPART B) 68.20 - 68.42

Hazard Assessment: Applicability [68.2]

ì

3.1. Has the owner or operator prepared a worst-case release

scenario analysis as provided in 68.25 and completed the fiveyear accident history as provided in 68.42? [68.2]

Hazard Assessment: Offsite consequence analysis parameters [68.22]

Has the owner or operator:

3.2. Used the following endpoints for offsite consequence analysis

for a worst-case scenario: [68.22(a)]

ì

3.2.1. For toxics: the endpoints provided in Appendix A of 40 CFR 

Part 68? [68.22(a)(1)]

ì

3.2.2. For flammables: an explosion resulting in an overpressure of 1

psi? [68.22(a)(2)(i)]

3.3. Used the following endpoints for offsite consequence analysis

for an alternative release scenario: [68.22(a)]

ì

3.3.1. For toxics: the endpoints provided in Appendix A of 40 CFR 

Part 68? [68.22(a)(1)]

ì

3.3.2. For flammables: an explosion resulting in an overpressure of 1

psi? [68.22(a)(2)(i)]

ì

3.3.3. For flammables: a fire resulting in a radiant heat/exposure of 5

kw/m2 for 40 seconds? [68.22(a)(2)(ii)]

ì

3.3.4. For flammables: a concentration resulting in a lower

flammability limit, as provided in NFPA documents or other

generally recognized sources? [68.22(a)(2)(iii)]

ì

3.4. Used appropriate wind speeds and stability classes for the

release analysis? [68.22(b)]

ì

3.5. Used appropriate ambient temperature and humidity values for

the release analysis? [68.22(c)]

ì

3.6. Used appropriate values for the height of the release for the

release analysis? [68.22(d)]

ì

3.7. Used appropriate surface roughness values for the release

analysis? [68.22(e)]
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ì

3.8. Do tables and models, used for dispersion analysis of toxic

substances, appropriately account for dense or neutrally

buoyant gases? [68.22(f)]

ì

3.9. Were liquids, other than gases liquefied by refrigeration only,

considered to be released at the highest daily maximum

temperature, based on data for the previous three years

appropriate for a stationary source, or at process temperature,

whichever is higher? [68.22(g)]

Hazard Assessment: Worst-case release scenario analysis [68.25]

Has the owner or operator of Program 1 processes:

ì

3.10. Analyzed and reported in the RMP one worst-case scenario for

each Program 1 process? [68.25(a)(1)]

Has the owner or operator of Program 2 or 3 processes:

ì

3.11. Analyzed and reported in the RMP one worst-case release

scenario estimated to create the greatest distance to an endpoint

resulting from an accidental release of a regulated toxic

substance from covered processes under worst-case

conditions? [68.25(a)(2)(i)]

ì

3.12. Analyzed and reported in the RMP one worst-case release

scenario estimated to create the greatest distance to an endpoint

resulting from an accidental release of a regulated flammable

substance from covered processes under worst-case

conditions? [68.25(a)(2)(ii)]

ì

3.13. Analyzed and reported in the RMP additional worst-case

release scenarios for a hazard class if the a worst-case release

from another covered process at the stationary source

potentially affects public receptors different from those

potentially affected by the worst-case release scenario

developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)?

[68.25(a)(2)(iii)]

Has the owner or operator:

3.14. Determined the worst-case release quantity to be the greater of

the following: [68.25(b)]
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ì

3.14.1. If released from a vessel, the greatest amount held in a single

vessel, taking into account administrative controls that limit the

maximum quantity ? [68.25(b)(1)]

ì

3.14.2. If released from a pipe, the greatest amount held in the pipe,

taking into account administrative controls that limit the

maximum quantity? [68.25(b)(2)]

Has the owner or operator:

For toxic substances that are normally gases at ambient temperature and

handled as a gas or liquid under pressure:

ì

3.15. Assumed the whole quantity in the vessel or pipe would be

released as a gas over 10 minutes? [68.25(c)(1)]

ì

3.16. Assumed the release rate to be the total quantity divided by 10,

if there are no passive mitigation systems in place?

[68.25(c)(1)]

Has the owner or operator:

For toxic gases handled as refrigerated liquids at ambient pressure:

ì

3.17. Assumed the substance would be released as a gas in 10

minutes, if not contained by passive mitigation systems or if

the contained pool would have a depth of 1 cm or less?

[68.25(c)(2)(i)]

ì

3.18. [ Optional for owner / operator ] Assumed the quantity in the

vessel or pipe would be spilled instantaneously to form a liquid

pool, if the released substance would be contained by passive

mitigation systems in a pool with a depth greater than 1 cm?

[68.25(c)(2)(ii)]

ì

3.19. Calculated the volatilization rate at the boiling point of the

substance and at the conditions specified in 68.25(d)?

[68.25(c)(2)(ii)]

Has the owner or operator:

For toxic substances that are normally liquids at ambient temperature:

ì

3.20. Assumed the quantity in the vessel or pipe would be spilled

instantaneously to form a liquid pool? [68.25(d)(1)]

ì

3.21. Determined the surface area of the pool by assuming that the

liquid spreads to 1 cm deep, if there is no passive mitigation

system in place that would serve to contain the spill and limit

the surface area, or if passive mitigation is in place, the surface

area of the contained liquid shall be used to calculate the

volatilization rate? [68.25(d)(1)(i)]
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ì

3.22. Taken into account the actual surface characteristics, if the

release would occur onto a surface that is not paved or smooth?

[68.25(d)(1)(ii)]

ì

3.23. Determined the volatilization rate by accounting for the highest

daily maximum temperature in the past three years, the

temperature of the substance in the vessel, and the

concentration of the substance if the liquid spilled is a mixture

or solution? [68.25(d)(2)]

ì

3.24. Determined the rate of release to air from the volatilization rate

of the liquid pool? [68.25(d)(3)]

ì

3.25. Determined the rate of release to air by using the methodology

in the RMP Offsite Consequence Analysis Guidance, any other

publicly available techniques that account for the modeling

conditions and are recognized by industry as applicable as part

of current practices, or proprietary models that account for the

modeling conditions may be used provided the owner or

operator allows the implementing agency access to the model

and describes model features and differences from publicly

available models to local emergency planners upon request.

[68.25(d)(3)]

Has the owner or operator:

For flammables:

ì

3.26.1. Assumed the quantity in a vessel(s) of flammable gas held as a

gas or liquid under pressure or refrigerated gas released to an

undiked area vaporizes resulting in a vapor cloud explosion? 

[68.25(e)]

ì

3.26.2. For refrigerated gas released to a contained area or liquids

released below their atmospheric boiling point, assumed the

quantity volatilized in 10 minutes results in a vapor cloud.

[68.25(f)]

ì

3.27. Assumed a yield factor of 10% of the available energy is

released in the explosion for determining the distance to the

explosion endpoint, if the model used is based on

TNT-equivalent methods? [68.25(e)]

Has the owner or operator:

ì

3.28. Used the parameters defined in 68.22 to determine distance to

the endpoints? [68.25(g)]
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ì

3.29. Determined the rate of release to air by using the methodology

in the RMP Offsite Consequence Analysis Guidance, any other

publicly available techniques that account for the modeling

conditions and are recognized by industry as applicable as part

of current practices, or proprietary models that account for the

modeling conditions may be used provided the owner or

operator allows the implementing agency access to the model

and describes model features and differences from publicly

available models to local emergency planners upon request.

[68.25(g)]

ì

3.29.1 What modeling technique did the owner or operator use?

[68.25(g)]

ì

3.30. Ensured that the passive mitigation system, if considered, is

capable of withstanding the release event triggering the

scenario and will still function as intended? [68.25(h)]

ì

3.31. Considered also the following factors in selecting the

worst-case release scenarios: [68.25(i)]

ì

3.31.1. Smaller quantities handled at higher process temperature or

pressure? [68.25(i)(1)]

ì

3.31.2. Proximity to the boundary of the stationary source? 

[68.25(i)(2)]

Hazard Assessment: Alternative release scenario analysis [68.28]

Has the owner or operator:

ì

3.32. Identified and analyzed at least one alternative release scenario

for each regulated toxic substance held in a covered

process(es) and at least one alternative release scenario to

represent all flammable substances held in covered processes?

[68.28(a)]

3.33. Selected a scenario: [68.28(b)]

ì

3.33.1. That is more likely to occur than the worst-case release

scenario under 68.25? [68.28(b)(1)(i)]

ì

3.33.2. That will reach an endpoint off-site, unless no such scenario

exists? [68.28(b)(1)(ii)]

3.34. Considered release scenarios which included, but are not

limited to, the following: [68.28(b)(2)]
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ì

3.34.1. Transfer hose releases due to splits or sudden hose uncoupling?

[68.28(b)(2)(i)]

ì

3.34.2. Process piping releases from failures at flanges , joints, welds,

valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)]

ì

3.34.3. Process vessel or pump releases due to cracks, seal failure, or

drain, bleed, or plug failure? [68.28(b)(2)(iii)]

ì

3.34.4. Vessel overfilling and spill, or overpressurization and venting

through relief valves or rupture disks? [68.28(b)(2)(iv)]

ì

3.34.5. Shipping container mishandling and breakage or puncturing

leading to a spill? [68.28(b)(2)(v)]

ì

3.35. Used the parameters defined in 68.22 to determine distance to

the endpoints? [68.28(c)]

ì

3.36. Determined the rate of release to air by using the methodology

in the RMP Offsite Consequence Analysis Guidance, any other

publicly available techniques that account for the modeling

conditions and are recognized by industry as applicable as part

of current practices, or proprietary models that account for the

modeling conditions may be used provided the owner or

operator allows the implementing agency access to the model

and describes model features and differences from publicly

available models to local emergency planners upon request.

[68.28(c)]

ì

3.37. Ensured that the passive and active mitigation systems, if

considered, are capable of withstanding the release event

triggering the scenario and will be functional? [68.28(d)]

3.38. Considered the following factors in selecting the alternative

release scenarios: [68.25(e)]

ì

3.38.1. The five-year accident history provided in 68.42? [68.25(e)(1)]

ì

3.38.2. Failure scenarios identified under 68.50 or 68.67? 

[68.25(e)(2)]
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Hazard Assessment: Defining off-site impacts -- population [68.3]

Has the owner or operator:

ì

3.39. Estimated population that would be included in the distance to

the endpoint in the RMP based on a circle with the point of

release at the center? [68.30(a)]

ì

3.40. Identified the presence of institutions, parks and recreational

areas, major commercial, office, and industrial buildings in the

RMP? [68.30(b)]

ì

3.41. Used most recent Census data, or other updated information to

estimate the population? [68.30(c)]

ì

3.42. Estimated the population to two significant digits? [68.30(d)]

Hazard Assessment: Defining off-site impacts -- environment [68.33]

Has the owner or operator:

ì

3.43. Identified environmental receptors that would be included in

the distance to the endpoint based on a circle with the point of

release at the center? [68.33(a)]

ì

3.44. Relied on information provided on local U.S.G.S. maps, or on

any data source containing U.S.G.S. data to identify

environmental receptors? [ Source may have used LandView to

obtain information ] [68.33(b)]

Hazard Assessment: Review and update [68.36]

Has the owner or operator:

ì

3.45. Reviewed and updated the off-site consequence analyses at

least once every five years? [68.36(a)]

ì

3.46. Completed a revised analysis and submit a revised RMP within

six months of a change in processes, quantities stored or

handled, or any other aspect that might reasonably be expected

on increase or decrease the distance to the endpoint by a factor

of two or more? [68.36(b)]
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Hazard Assessment: Documentation [68.39]

Has the owner or operator maintained records of the following:

ì

3.47. For worst-case scenarios: a description of the vessel or pipeline

and substance selected, assumptions and parameters used, the

rationale for selection, and anticipated effect of the

administrative controls and passive mitigation on the release

quantity and rate? [68.39(a)]

ì

3.48. For alternative release scenarios: a description of the scenarios

identified, assumptions and parameters used, the rationale for

the selection of specific scenarios, and anticipated effect of the

administrative controls and mitigation on the release quantity

and rate? [68.39(b)]

ì

3.49. Documentation of estimated quantity released, release rate, and

duration of release? [68.39(c)]

ì

3.50. Methodology used to determine distance to endpoints?

[68.39(d)]

ì

3.51. Data used to estimate population and environmental receptors

potentially affected? [68.39(e)]

Hazard Assessment: Five-year accident history [68.42]

ì

3.52. Has the owner or operator included all accidental releases from

covered processes that resulted in deaths, injuries, or

significant property damage on site, or known offsite deaths,

injuries, evacuations, sheltering in place, property damage, or

environmental damage? [68.42(a)]

3.53. Has the owner or operator reported the following information

for each accidental release: [68.42(b)]

ì

3.53.1. Date, time, and approximate duration of the release?

[68.42(b)(1)]

ì

3.53.2. Chemical(s) released? [68.42(b)(2)]

ì

3.53.3. Estimated quantity released in pounds and percentage weight

in a mixture (toxics)? [68.42(b)(3)]
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ì

3.53.4. NAICS code for the process? [68.42(b)(4)]

ì

3.53.5. The type of release event and its source? [68.42(b)(5)]

ì

3.53.6. Weather conditions (if known)? [68.42(b)(6)]

ì

3.53.7. On-site impacts? [68.42(b)(7)]

ì

3.53.8. Known offsite impacts? [68.42(b)(8)]

ì

3.53.9. Initiating event and contributing factors (if known)?

[68.42(b)(9)]

ì

3.53.10. Whether offsite responders were notified (if known)?

[68.42(b)(10)]

ì

3.53.11. Operational or process changes that resulted from investigation

of the release? [68.42(b)(11)]

General Findings / Conclusions:

Documentation obtained to support Findings / Conclusions:
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4. PROGRAM 2 PREVENTION PROGRAM

 (SUBPART C) [68.48 - 68.60]

Program 2 Prevention - Safety information [68.48]

Has the owner or operator:

4.1. Compiled and maintained the following up-to-date safety

information, related to the regulated substances, processes, and

equipment: [68.48(a)]

ì

4.1.1. Material Safety Data Sheets (MSDS) that meet the

requirements of the OSHA Hazard Communication Standard

[29 CFR 1910.1200(g)]? [68.48(a)(1)]

ì

4.1.2. Maximum intended inventory of equipment in which the

regulated substances are stored or processed? [68.48(a)(2)]

ì

4.1.3. Safe upper and lower temperatures, pressures, flows, and

compositions? [68.48(a)(3)]

ì

4.1.4. Equipment specifications? [68.48(a)(4)]

ì

4.1.5. Codes and standards used to design, build, and operate the

process? [68.48(a)(5)]

ì

4.2. Ensured the process is designed in compliance with recognized

and generally accepted good engineering practices? [68.48(b)]

ì

4.3. Updated information if a major change has occurred that made

the information inaccurate? [68.48(c)]

Program 2 Prevention - Hazard review [68.5]

ì

4.4. Has the owner or operator conducted a review of the hazards

associated with the regulated substances, processes, and

procedures? [68.50(a)]

4.5. Did the review identify:
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ì

4.5.1. The hazards associated with the process and regulated

substances? [68.50(a)(1)]

ì

4.5.2. Opportunities for equipment malfunctions or human errors that

could cause an accidental release? [68.50(a)(2)]

ì

4.5.3. The safeguards used or needed to control the hazards or

prevent equipment malfunctions or human error? [68.50(a)(3)]

ì

4.5.4. Any steps used or needed to detect or monitor releases?

[68.50(a)(4)]

Has the owner or operator:

ì

4.6. Determined by inspecting all equipment that the processes are

designed, fabricated, and operated in accordance with

applicable standards or rules, if designed to meet industry

standards or Federal or state design rules? [68.50(b)]

ì

4.7. Documented the results of the review? [68.50(c)]

ì

4.8. Ensured that problems identified were resolved in a timely

manner? [68.50(c)]

ì

4.9. Updated the review at least once every five years or whenever

a major change in the processes occurred? [68.50(d)]

ì

4.10. Resolved all issues identified in the review before startup of

the changed process? [68.50(d)]

Program 2 Prevention - Operating procedures [68.52]

ì

4.11. Has the owner or operator prepared written operating

procedures that provide clear instructions or steps for safely

conducting activities associated with each covered process

consistent with the safety information for that process? 

Operating procedures or instructions provided by equipment

manufacturers or developed by persons or organizations

knowledgeable about the process and equipment may be used

as a basis for a stationary source’s operating procedures.

[68.52(a)]

4.12. Do the procedures address the following: [68.52(b)]

ì

4.12.1. Initial startup? [68.52(b)(1)]
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ì

4.12.2. Normal operations? [68.52(b)(2)]

ì

4.12.3. Temporary operations? [68.52(b)(3)]

ì

4.12.4. Emergency shutdown and operations? [68.52(b)(4)]

ì

4.12.5. Normal shutdown? [68.52(b)(5)]

ì

4.12.6. Startup following a normal or emergency shutdown or a major

change that requires a hazard review? [68.52(b)(6)]

ì

4.12.7. Consequences of deviations and steps required to correct or

avoid deviations? [68.52(b)(7)]

ì

4.12.8. Equipment inspections? [68.52(b)(8)]

ì

4.13. Has the owner or operator ensured that the operating

procedures have been updated, if necessary, whenever a major

change occurred and prior to startup of the changed process?

[68.52(c)
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Program 2 Prevention - Training [68.54]

Has the owner or operator:

ì

4.14. Certified that each employee presently operating a process, and

each employee newly assigned to a covered process have been

trained or tested competent in the operating procedures

provided in § 68.52 that pertain to their duties? For those

employees already operating a process on June 21, 1999, the

owner or operator may certify in writing that the employee has

the required knowledge, skills, and abilities to safely carry out

the duties and responsibilities as provided in the operating

procedures. [68.54(a)]

ì

4.15. Provided refresher training at least every three years, or more

often if necessary, to each employee operating a process, to

ensure that the employee understands and adheres to the

current operating procedures of the process? [68.54(b)]

ì

4.16. Determined, in consultation with the employees operating the

process, the appropriate frequency of refresher training?

[68.54(b)]

ì

4.17. Certified that each employee was trained in any updated or

new procedures prior to startup of a process after a major

change? [68.54(d)]

Program 2 Prevention - Maintenance [68.56]

Has the owner or operator:

ì

4.18. Prepared and implemented procedures to maintain the

on-going mechanical integrity of the process equipment?

[68.56(a)]

ì

4.19. Trained or caused to be trained each employee, involved in

maintaining the on-going mechanical integrity of the process,

in the hazards of the process, in how to avoid or correct unsafe

conditions, and in the procedures applicable to the employee's

job tasks? [68.56(b)]

ì

4.20. Has every maintenance contractor ensured that each contract

maintenance employee is trained to perform the maintenance

procedures developed? [68.56(c)]
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ì

4.21. Has the owner or operator performed or caused to be

performed inspections and tests on process equipment that

follow recognized and generally accepted engineering

practices? [68.56(d)]

Program 2 Prevention - Compliance audits [68.58]

ì

4.22. Has the owner or operator certified that compliance audits are

conducted at least every three years to verify that the

procedures and practices are adequate and are being followed?

[68.58(a)]

ì

4.23. Has compliance audit been conducted by at least one person

knowledgeable in the process? [68.58(b)]

ì

4.24. Has the owner operator developed a report of the audits

findings? [68.58(c)]

ì

4.25. Has the owner or operator promptly determined and

documented an appropriate response to each of the findings of

the audit and documented that deficiencies had been corrected?

[68.58(d)]

ì

4.26. Has the owner or operator retained the two most recent

compliance audit reports, unless more than five years old?

[68.58(e)]

Program 2 Prevention - Incident investigation [68.6]

ì

4.27. Has the owner or operator investigated each incident which

resulted in, or could reasonably have resulted in a catastrophic

release? [68.60(a)]

ì

4.28. Were all incident investigations initiated not later than 48 hours

following the incident? [68.60(b)]

4.29. Was a summary prepared at the conclusion of every

investigation, which included: [68.60(c)]

ì

4.29.1. Date of incident? [68.60(c)(1)]
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ì

4.29.2. Date investigation began? [68.60(c)(2)]

ì

4.29.3. A description of incident? [68.60(c)(3)]

ì

4.29.4. The factors that contributed to the incident? [68.60(c)(4)]

ì

4.29.5. Any recommendations resulting from the investigation?

[68.60(c)(5)]

ì

4.30. Has the owner or operator promptly addressed and resolved the

investigation findings and recommendations, and are the

resolutions and corrective actions documented? [68.60(d)]

ì

4.31. Has the owner or operator reviewed the finding with all

affected personnel whose job tasks are affected by the

findings? [68.60(e)]

ì

4.32. Has the owner or operator retained investigation summaries for

five years? [68.60(f)]

General Findings / Conclusions:

Documentation obtained to support Findings / Conclusions:
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5. PROGRAM 3 PREVENTION PROGRAM 

 (SUBPART D) [68.65 - 68.87]

Program 3 Prevention - Process safety information [68.65]

ì

5.1. Has the owner or operator compiled written process safety

information, which includes information pertaining to the

hazards of the regulated substances used or produced by the

process, information pertaining to the technology of the

process, and information pertaining to the equipment in the

process, before conducting any process hazard analysis

required by the rule? [68.65(a)]

5.2. Does the process safety information contain the following for

hazards of the substances: [68.65(b)]

ì

5.2.1. Toxicity information? [68.65(b)(1)]

ì

5.2.2. Permissible exposure limits? [68.65(b)(2)]

ì

5.2.3. Physical data? [68.65(b)(3)]

ì

5.2.4. Reactivity data? [68.65(b)(4)]

ì

5.2.5. Corrosivity data? [68.65(b)(5)]

ì

5.2.6. Thermal and chemical stability data? [68.65(b)(6)]

ì

5.2.7. Hazardous effects of inadvertent mixing of materials that could

foreseeably occur? [68.65(b)(7)]

5.3. Does the process safety information contain the following for

technology of the process: [68.65(c)(1)]

ì

5.3.1. A block flow diagram or simplified process flow diagram?

[68.65(c)(1)(i)]
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ì

5.3.2. Process chemistry? [68.65(c)(1)(ii)]

ì

5.3.3. Maximum intended inventory? [68.65(c)(1)(iii)]

ì

5.3.4. Safe upper and lower limits for such items as temperatures,

pressures, flows or compositions? [68.65(c)(1)(iv)]

ì

5.3.5. An evaluation of the consequences of deviations?

[68.65(c)(1)(v)]

5.4. Does the process safety information contain the following for

the equipment in the process: [68.65(d)(1)]

ì

5.4.1. Materials of construction? [68.65(d)(1)(i)]

ì

5.4.2. Piping and instrument diagrams? [68.65(d)(1)(ii)]

ì

5.4.3. Electrical classification? [68.65(d)(1)(iii)]

ì

5.4.4. Relief system design and design basis? [68.65(d)(1)(iv)]

ì

5.4.5. Ventilation system design? [68.65(d)(1)(v)]

ì

5.4.6. Design codes and standards employed? [68.65(d)(1)(vi)]

ì

5.4.7. Material and energy balances for processes built after June 21,

1999? [68.65(d)(1)(vii)]

ì

5.4.8. Safety systems? [68.65(d)(1)(viii)]

ì

5.5. Has the owner or operator documented that equipment

complies with recognized and generally accepted good

engineering practices? [68.65(d)(2)]

ì

5.6. Has the owner or operator determined and documented that

existing equipment, designed and constructed in accordance

with codes, standards, or practices that are no longer in general

use, is designed, maintained, inspected, tested, and operating in

a safe manner? [68.65(d)(3)]
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Program 3 Prevention - Process hazard analysis [68.67]

ì

5.7. Has the owner or operator performed an initial process hazard

analysis (PHA), and has this analysis identified, evaluated, and

controlled the hazards involved in the process? [68.67(a)]

ì

5.8. Has the owner or operator determined and documented the

priority order for conducting PHAs, and was it based on a

appropriate rationales? [68.67(a)]

ì

5.9. Has the owner or operator used one or more of the following

technologies: [68.67(b)]

ì

5.9.1. What-If? [68.67(b)(1)]

ì

5.9.2. Checklist? [68.67(b)(2)]

ì

5.9.3. What-If/Checklist? [68.67(b)(3)]

ì

5.9.4. Hazard and Operability Study (HAZOP)? [68.67(b)(4)]

ì

5.9.5. Failure Mode and Effects Analysis (FMEA)? [68.67(b)(5)]

ì

5.9.6. Fault Tree Analysis? [68.67(b)(6)]

ì

5.9.7. An appropriate equivalent methodology? [68.67(b)(7)]

5.10. Did the PHA address: [68.67(c)]

ì

5.10.1. The hazards of the process? [68.67(c)(1)]

ì

5.10.2. Identification of any incident which had a likely potential for

catastrophic consequences? [68.67(c)(2)]
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ì

5.10.3. Engineering and administrative controls applicable to hazards

and interrelationships? [68.67(c)(3)]

ì

5.10.4. Consequences of failure of engineering and administrative

controls? [68.67(c)(4)]

ì

5.10.5. Stationary source siting? [68.67(c)(5)]

ì

5.10.6. Human factors? [68.67(c)(6)]

ì

5.10.7. An evaluation of a range of the possible safety and health

effects of failure of controls? [68.67(c)(7)]

ì

5.11. Was the PHA performed by a team with expertise in

engineering and process operations and did the team include

appropriate personnel? [68.67(d)]

ì

5.12. Has the owner or operator established a system to promptly

address the team's findings and recommendations; assured that

the recommendations are resolved in a timely manner and

documented; documented what actions are to be taken;

completed actions as soon as possible; developed a written

schedule of when these actions are to be completed; and

communicated the actions to operating, maintenance and other

employees whose work assignments are in the process and who

may be affected by the recommendations? [68.67(e)]

ì

5.13. Has the PHA been updated and revalidated by a team every

five years after the completion of the initial PHA to assure that

the PHA is consistent with the current process? [68.67(f)]

ì

5.14. Has the owner or operator retained PHAs and updates or

revalidations for each process covered, as well as the resolution

of recommendations for the life of the process? [68.67(g)]

Program 3 Prevention - Operating procedures [68.69]

ì

5.15. Has the owner or operator developed and implemented written

operating procedures that provide instructions or steps for

conducting activities associated with each covered process

consistent with the safety information? [68.69(a)]

5.16. Do the procedures address the following: [68.69(a)]
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5.16.1. Steps for each operating phase: [68.69(a)(1)]

ì

5.16.1.1. Initial startup? [68.69(a)(1)(i)]

ì

5.16.1.2. Normal operations? [68.69(a)(1)(ii)]

ì

5.16.1.3. Temporary operations? [68.69(a)(1)(iii)]

ì

5.16.1.4. Emergency shutdown including the conditions under which

emergency shutdown is required, and the assignment of

shutdown responsibility to qualified operators to ensure that

emergency shutdown is executed in a safe and timely manner?

[68.69(a)(1)(iv)]

ì

5.16.1.5. Emergency operations? [68.69(a)(1)(v)]

ì

5.16.1.6. Normal shutdown? [68.69(a)(1)(vi)]

ì

5.16.1.7. Startup following a turnaround, or after emergency shutdown?

[68.69(a)(1)(vii)]

5.16.2. Operating limits: [68.69(a)(2)]

ì

5.16.2.1. Consequences of deviations? [68.69(a)(2)(i)]

ì

5.16.2.2. Steps required to correct or avoid deviation? [68.69(a)(2)(ii)]

5.16.3. Safety and health considerations: [68.69(a)(3)]

ì

5.16.3.1. Properties of, and hazards presented by, the chemicals used in

the process? [68.69(a)(3)(i)]

ì

5.16.3.2. Precautions necessary to prevent exposure, including

engineering controls, administrative controls, and personal

protective equipment? [68.69(a)(3)(ii)]
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ì

5.16.3.3. Control measures to be taken if physical contact or airborne

exposure occurs? [68.69(a)(3)(iii)]

ì

5.16.3.4. Quality control for raw materials and control of hazardous

chemical inventory levels? [68.69(a)(3)(iv)]

ì

5.16.3.5. Any special or unique hazards? [68.69(a)(3)(v)]

ì

5.16.4. Safety systems and their functions? [68.69(a)(4)]

ì

5.17. Are operating procedures readily accessible to employees who

are involved in a process? [68.69(b)]

ì

5.18. Has the owner or operator certified annually that the operating

procedures are current and accurate and that procedures have

been reviewed as often as necessary? [68.69(c)]

ì

5.19. Has the owner or operator developed and implemented safe

work practices to provide for the control of hazards during

specific operations, such as logout/tagout? [68.69(d)]

Program 3 Prevention - Training [68.71]

ì

5.20. Has each employee presently involved in operating a process,

and each employee before being involved in operating a newly

assigned process, been initially trained in an overview of the

process and in the operating procedures? [68.71(a)(1)]

ì

5.21. Did initial training include emphasis on safety and health

hazards, emergency operations including shutdown, and safe

work practices applicable to the employee's job tasks? 

[68.71(a)(2) allows in lieu of initial training for those employees already

involved in operating a process on June 21, 1999 an owner or operator may

certify in writing that the employee has the required knowledge, skills, and

abilities to safely carry out the duties and responsibilities as specified in the

operating procedures] [68.71(a)(1)

ì

5.22. Has refresher training been provided at least every three years,

or more often if necessary, to each employee involved in

operating a process to assure that the employee understands

and adheres to the current operating procedures of the process?

[68.71(b)

ì

5.23. Has owner or operator ascertained and documented in a record

that each employee involved in operating a process has

received and understood the training required? [68.71(c)]
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ì

5.24. Does the prepared record contain the identity of the employee,

the date of training, and the means used to verify that the

employee understood the training? [68.71(c)]

Program 3 Prevention - Mechanical integrity [68.73]

ì

5.25. Has the owner or operator established and implemented written

procedures to maintain the on-going integrity of the process

equipment listed in 68.73(a)? [68.73(b)]

ì

5.26. Has the owner or operator trained each employee involved in

maintaining the on-going integrity of process equipment? 

[68.73(c)]

Has the owner or operator:

ì

5.27. Performed inspections and tests on process equipment?

[68.73(d)(1)]

ì

5.28. Followed recognized and generally accepted good engineering

practices for inspection and testing procedures? [68.73(d)(2)]

ì

5.29. Ensured the frequency of inspections and tests of process

equipment is consistent with applicable manufacturers'

recommendations, good engineering practices, and prior

operating experience? [68.73(d)(3)]

ì

5.30. Documented each inspection and test that had been performed

on process equipment, which identifies the date of the

inspection or test, the name of the person who performed the

inspection or test, the serial number or other identifier of the

equipment on which the inspection or test was performed, a

description of the inspection or test performed, and the results

of the inspection or test? [68.73(d)(4)]

ì

5.31. Corrected deficiencies in equipment that were outside

acceptable limits defined by the process safety information

before further use or in a safe and timely manner when

necessary means were taken to assure safe operation? 

[68.73(e)]

ì

5.32. Assured that equipment as it was fabricated is suitable for the

process application for which it will be used in the construction

of new plants and equipment? [68.73(f)(1)]
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ì

5.33. Performed appropriate checks and inspections to assure that

equipment was installed properly and consistent with design

specifications and the manufacturer's instructions?

[68.73(f)(2)]

ì

5.34. Assured that maintenance materials, spare parts and equipment

were suitable for the process application for which they would

be used? [68.73(f)(3)]

Program 3 Prevention - Management of change [68.75]

ì

5.35. Has the owner or operator established and implemented written

procedures to manage changes to process chemicals,

technology, equipment, and procedures, and changes to

stationary sources that affect a covered process? [68.75(a)]

5.36. Do procedures assure that the following consideration are

addressed prior to any change: [68.75(b)]

ì

5.36.1. The technical basis for the proposed change? [68.75(b)(1)]

ì

5.36.2. Impact of change on safety and health? [68.75(b)(2)]

ì

5.36.3. Modifications to operating procedures? [68.75(b)(3)]

ì

5.36.4. Necessary time period for the change? [68.75(b)(4)]

ì

5.36.5. Authorization requirements for the proposed change?

[68.75(b)(5)]

ì

5.37. Were employees, involved in operating a process and

maintenance, and contract employees, whose job tasks would

be affected by a change in the process, informed of, and trained

in, the change prior to start-up of the process or affected part of

the process? [68.75(c)]

ì

5.37. If a change resulted in a change in the process safety

information, was such information updated accordingly?

[68.75(d)]

ì

5.38. If a change resulted in a change in the operating procedures or

practices, had such procedures or practices been updated

accordingly? [68.75(e)]
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 Program 3 Prevention - Pre-startup review [68.77]

ì

5.39. Has the owner or operator performed a pre-startup safety

review for new stationary sources and for modified stationary

sources when the modification was significant enough to

require a change in the process safety information,? [68.77(a)]

5.40. Did the pre-startup safety review confirm that prior to the

introduction of regulated substances to a process: [68.77(b)]

ì

5.40.1. Construction and equipment was in accordance with design

specifications? [68.77(b)(1)]

ì

5.40.2. Safety, operating, maintenance, and emergency procedures

were in place and were adequate? [68.77(b)(2)]

ì

5.40.3. For new stationary sources, a process hazard analysis had been

performed and recommendations had been resolved or

implemented before startup? [68.77(b)(3)]

ì

5.40.4. Modified stationary sources meet the requirements contained in

management of change? [68.77(b)(3)]

ì

5.40.5. Training of each employee involved in operating a process had

been completed? [68.77(b)(4)]

Program 3 Prevention - Compliance audits [68.79]

ì

5.41. Has the owner or operator certified that the stationary source

has evaluated compliance with the provisions of the prevention

program at least every three years to verify that the developed

procedures and practices are adequate and are being followed?

[68.79(a)]

ì

5.42. Has the audit been conducted by at least one person

knowledgeable in the process? [68.79(b)]

ì

5.43. Are the audits findings documented in report? [68.79(c)]
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ì

5.44. Has the owner or operator promptly determined and

documented an appropriate response to each of the findings of

the audit and documented that deficiencies had been corrected?

[68.79(d)]

ì

5.45. Has the owner or operator retained the two most recent

compliance audit reports? [68.79(e)]

Program 3 Prevention - Incident investigation [68.81]

ì

5.46. Has the owner or operator investigated each incident which

resulted in, or could reasonably have resulted in a catastrophic

release of a regulated substance? [68.81(a)]

ì

5.47. Were all incident investigations initiated not later than 48 hours

following the incident? [68.81(b)]

ì

5.48. Was an incident investigation team established and did it

consist of at least one person knowledgeable in the process

involved, including a contract employee if the incident

involved work of the contractor, and other persons with

appropriate knowledge and experience to thoroughly

investigate and analyze the incident? [68.81(c)]

ì

5.49. Was a report prepared at the conclusion of every investigation?

[68.81(d)]

5.50. Does every report include: [68.81(d)]

ì

5.51.1. Date of incident? [68.81(d)(1)]

ì

5.51.2. Date investigation began? [68.81(d)(2)]

ì

5.51.3. A description of the incident? [68.81(d)(3)]

ì

5.51.4. The factors that contributed to the incident? [68.81(d)(4)]

ì

5.51.5. Any recommendations resulting from the investigation?

[68.81(d)(5)]

ì

5.52. Has the owner or operator established a system to address and

resolve the report findings and recommendations, and are the

resolutions and corrective actions documented? [68.81(e)]
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ì

5.53. Was the report reviewed with all affected personnel whose job

tasks are relevant to the incident findings including contract

employees where applicable? [68.81(f)]

Program 3 Prevention - Employee participation [68.83]

Has the owner or operator:

ì

5.54. Developed a written plan of action regarding the

implementation of the employee participation required by this

section? [68.83(a)]

ì

5.55. Consulted with employees and their representatives on the

conduct and development of process hazards analyses and on

the development of the other elements of process safety

management in chemical accident prevention provisions?

[68.83(b)]

ì

5.56. Provided to employees and their representatives access to

process hazard analyses and to all other information required to

be developed under chemical accident prevention rule?

[68.83(c)]

Program 3 Prevention - Hot work permit [68.85]

ì

5.57. Has the owner or operator issued a hot work permit for each

hot work operation conducted on or near a covered process?

[68.85(a)]

ì

5.58. Does the permit document that the fire prevention and

protection requirements in 29 CFR 1910.252(a) have been

implemented prior to beginning the hot work operations?

[68.85(b)]

ì

5.59. Does the permit indicate the date(s) authorized for hot work

and the object on which hot works to be performed? [68.85(b)]

ì

5.60. Are the permits being kept on file until completion of the hot

work operations? [68.85(b)]
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Program 3 Prevention - Contractors [68.87]

Has the owner or operator: [68.87(b)]

ì

5.61. Obtained and evaluated information regarding the contract

owner or operator's safety performance and programs when

selecting a contractor,? [68.87(b)(1)]

ì

5.62. Informed contract owner or operator of the known potential

fire, explosion, or toxic release hazards related to the

contractor's work and the process? [68.87(b)(2)]

ì

5.63. Explained to the contract owner or operator the applicable

provisions of emergency response program? [68.87(b)(3)]

ì

5.64. Developed and implemented safe work practices consistent

with §68.69(d), to control the entrance, presence, and exit of

the contract owner or operator and contract employees in

covered process areas? [68.87(b)(4)]

General Findings / Conclusions:

Documentation obtained to support Findings / Conclusions:

6. EMERGENCY RESPONSE (SUBPART E) 68.90 - 68.95

Emergency Response - Applicability [68.9]

ì

6.1. Has the owner or operator of a stationary source developed an

emergency response program, unless the source need not

comply? [68.90(a)]

If the employees of the stationary source will not respond to accidental

releases of regulated substances:
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C-41

ì

6.2. For stationary sources with any regulated toxic substance held

in a process above the threshold quantity, is the stationary

source included in the community emergency response plan

developed under EPCRA? [68.90(b)(1)]

ì

6.3. For stationary sources with only regulated flammable

substances held in a process above the threshold quantity, has

the owner or operator coordinated response actions with the

local fire department? [68.90(b)(2)]

ì

6.4. Are appropriate mechanisms in place to notify emergency

responders when there is a need for a response? [68.90(b)(3)]

Emergency Response - Applicability [68.9]

ì

6.5. Has the owner or operator developed and implemented an

emergency response program for the purpose of protecting

public health and the environment? [68.95(a)]

6.6. Does the program include the following elements: [68.95(a)]

ì

6.6.1. An emergency response plan which is maintained at the

stationary source? [68.95(a)(1)]

ì

6.6.2. Procedures for the use of emergency response equipment and

for its inspection, testing, and maintenance? [68.95(a)(2)]

ì

6.6.3. Training for all employees in relevant procedures?

[68.95(a)(3)]

ì

6.6.4. Procedures to review and update, as appropriate, the

emergency response plan to reflect changes at the stationary

source and ensure that employees are informed of changes? 

[68.95(a)(4)]

6.7. Does the emergency response plan contain the following

elements: [68.95(a)(1)]

ì

6.7.1. Procedures for informing the public and local emergency

response agencies about accidental releases? [68.95(a)(1)(i)]

ì

6.7.2. Documentation of proper first-aid and emergency medical

treatment necessary to treat accidental human exposures?

[68.95(a)(1)(ii)]
Guidance for Auditing Risk Management Plans & Programs

COMPLIANCE OBJECTIVES NOTES

C-42

ì

6.7.3. Procedures and measures for emergency response after an

accidental release of a regulated substance? [68.95(a)(1)(iii)]

ì

6.8. Did the owner or operator use a written plan that complies with

other Federal contingency plan regulations or is consistent with

the approach in the National Response Team’s Integrated

Contingency Plan Guidance (‘‘One Plan’’)? If so, does the

plan include the elements provided in paragraph (a) of 68.95,

and also complies with paragraph (c) of 68.95? [68.95(b)]

ì

6.9. Has the emergency response plan been coordinated with the

community emergency response plan developed under

EPCRA? [68.95(c)]

ì

6.10. Has the owner or operator provided to the local emergency

response officials information necessary for developing and

implementing the community emergency response plan

requested by the LEPC or emergency response officials?

[68.95(c)]

General Findings / Conclusions:

Documentation obtained to support Findings / Conclusions:
CAS Chemical Name RMP RMP PSM Toxic

Threshold Threshold Threshold Endpoint

Quantity Corrected Quantity 

(TQ) lbs. to Gals (TQ) lbs

D-1

D

List of Regulated

Substances

106-98-9 1-butene 10,000 **

97-00-7 1-chloro-2,4-dinitrobenzene 5,000

590-21-6 1-chloropropylene {1-propene, 1-chloro-} 10,000 **

109-67-1 1-pentene 10,000 1,869

57-14-7 1,1-dimethylhydrazine {Dimethylhydrazine} {Hydrazine, 1,1-dimethyl-} 15,000 2,271 1,000 0.012

106-99-0 1,3-butadiene 10,000 1,930

504-60-9 1,3-pentadiene 10,000 1,753

107-01-7 2-butene 10,000 **

590-18-1 2-butene-cis 10,000 1,929

624-64-6 2-butene-trans {2-butene, (E)} 10,000 1,983

557-98-2 2-chloropropylene {1-propene, 2-chloro-} 10,000 **

563-46-2 2-methyl-1-butene 10,000 1,844

115-11-7 2-methylpropene {1-propene, 2-methyl-} 10,000 2,031

646-04-8 2-pentene (E)- 10,000 1,827

627-20-3 2-pentene (Z)- 10,000 1,849

463-82-1 2,2-dimethylpropane {Propane, 2,2-dimethyl-} 10,000 2,028

97-02-9 2,4-dinitroaniline 5,000

563-45-1 3-methyl-1-butene 10,000 1,911

75-07-0 Acetaldehyde 10,000 1,536 2,500

74-86-2 Acetylene {Ethyne} 10,000 1,955

107-02-8 Acrolein {2-propenal} 5,000 714 150 0.0011

107-13-1 Acrylonitrile {2-propenenitrile} 20,000 2,994 0.076

814-68-6 Acrylyl Chloride {2-propenoyl Chloride} 5,000 527 250 0.0009

Varies Alkylaluminums 5,000

107-18-6 Allyl Alcohol {2-propen-1-ol} 15,000 2,105 0.036

107-05-1 Allyl Chloride 1,000

107-11-9 Allylamine {2-propen-1-amine} 10,000 1,577 1,000 0.0032

7664-41-7 Ammonia (Anhydrous) 10,000 1,758 10,000 0.14

7664-41-7 Ammonia (>=20% for RMP) (>44% for PSM) 20,000 2,723 15,000 0.14

7790-98-9 Ammonium Perchlorate 7,500

7787-36-2 Ammonium Permanganate 7,500

7784-34-1 Arsenous Trichloride 15,000 836 0.01

7784-42-1 Arsine {Arsenic Hydride} 1,000 45 100 0.0019

10294-34-5 Boron Trichloride {Borane, Trichloro-} 5,000 444 2,500 0.01

7637-07-2 Boron Triflouride {Borane, Trifluoro-} 5,000 374 250 0.028

353-42-4 Boron Triflouride Compound with Methyl Ether (1:1)

{Boron, Trifluoro[oxybis[methane]-,T-4} 15,000 1,451 0.023

7726-95-6 Bromine 10,000 386 1,500 0.0065

13863-41-7 Bromine Chloride 1,500

7787-71-5 Bromine Trifluoride 15,000

ANNEX D: RISK MANAGEMENT PROGRAM AND OSHA

PROCESS SAFETY MANAGEMENT: LIST OF REGULATED

SUBSTANCES (BY CHEMICAL NAME)
CAS Chemical Name RMP RMP PSM Toxic

Threshold Threshold Threshold Endpoint

Quantity Corrected Quantity 

(TQ) lbs. to Gals (TQ) lbs

Guidance for Auditing Risk Management Plans & Programs

7789-30-2 Bromine Pentafluoride 2,500

598-73-2 Bromotrifluorethylene {Ethene, Bromotrifluoro-} 10,000 **

106-97-8 Butane 10,000 1997

25167-67-3 Butene 10,000 2014

75-91-2 Butyl Hydroperoxide (Tertiary) 5,000

614-45-9 Butyl Perbenzoate 7,500

75-15-0 Carbon Disulfide 20,000 1897 0.16

463-58-1 Carbon Oxysulfide {Carbon Oxide Sulfide (Cos)} {Carbonyl Sulfide} 10,000 571

353-44-5 Carbonyl Fluoride 2,500

9004-70-0 Cellulose Nitrate (>12.6% Nitrogen for PSM) 2,500

7782-50-5 Chlorine 2,500 210 1,500 0.0087

10049-04-4 Chlorine Dioxide {Chlorine Oxide (ClO2)} 1,000 75 1,000 0.0028

7791-21-1 Chlorine Monoxide {Chlorine Oxide} 10,000

13637-63-3 Chlorine Pentrafluoride 1,000

7790-91-2 Chlorine Trifluoride 1,000

96-06-2 Chlorodiethylaluminum {Diethylaluminum Chloride} 5,000

67-66-3 Chloroform {Methane, Trichloro-} 20,000 1,616 0.49

542-88-1 Chloromethyl Ether {Bis(chloromethyl) Ether} {Methane, 1,000 91 100 0.00025

Oxybis[chloro-} {Dichloromethyl Ether}

107-30-2 Chloromethyl Methyl Ether {Methane, Chloromethoxy-} 5,000 565 500 0.0018

76-06-2 Chloropicrin 500

None Chloropicrin and Methyl Bromide Mixture 1,500

None Chloropicrin and Methyl Chloride Mixture 1,500

4170-30-3 Crotonaldehyde {2-butenal} 20,000 2,833 0.029

123-73-9 Crotonaldehyde, (E)- {2-butenal, (E)-} 20,000 2,810 0.029

80-15-9 Cumene Hydroperoxide 5,000

460-19-5 Cyanogen {Ethanedinitrile} 10,000 1,256 2,500

506-77-4 Cyanogen Chloride 10,000 980 500 0.03

675-14-9 Cyanuric Fluoride 100

108-91-8 Cyclohexylamine {Cyclohexanamine} 15,000 2,079 0.16

75-19-4 Cyclopropane 10,000 1,773

110-22-5 Diacetyl Peroxide (>70% for PSM) 5,000

334-88-3 Diazomethane 500

94-36-0 Dibenzoyl Peroxide 7,500

19287-45-7 Diborane {Diborane (6)} 2,500 ** 100 0.0011

110-05-4 Dibutyl Peroxide (Tertiary) 5,000

4109-96-0 Dichlorosilane {Silane, Dichloro-} 10,000 999 2,500

557-20-0 Diethylzinc 10,000

75-37-6 Difluoroethane {Ethane, 1,1-difluoro-} 10,000 1,261

105-64-6 Diisopropyl Peroxydicarbonate 7,500

105-74-8 Dilauroyl Peroxide 7,500

124-40-3 Dimethylamine {Methanamine, N-methyl-} 10,000 1,786 2,500

75-78-5 Dimethyldichlorosilane {Silane, Dichlorodimethyl-} 5,000 545 1,000 0.026

106-89-8 Epichlorohydrin {Oxirane, (Chloromethyl)-} 20,000 1,331 0.076

D-2
D-3

D

List of Regulated

Substances

CAS Chemical Name RMP RMP PSM Toxic

Threshold Threshold Threshold Endpoint

Quantity Corrected Quantity 

(TQ) lbs. to Gals (TQ) lbs

74-84-0 Ethane 10,000 2,195

107-00-6 Ethyl Acetylene {1-butyne} 10,000 1,767

75-00-3 Ethyl Chloride {Chloroethane} {Ethane, Chloro-} 10,000 1,323

60-29-7 Ethyl Ether {Ethane, 1,1’-oxybis-} 10,000 1,678

75-08-1 Ethyl Mercaptan {Ethanethiol} 10,000 1,451

1338-23-4 Ethyl Methyl Ketone Peroxide 5,000

109-95-5 Ethyl Nitrite {Nitrous Acid, Ethyl Ester} 10,000 1,331 5,000

75-04-7 Ethylamine {Monoethylamine} (Ethanamine} 10,000 1,762 7,500

74-85-1 Ethylene {Ethene} 10,000 2,106

371-62-0 Ethylene Fluorohydrin 100

75-21-8 Ethylene Oxide {Oxirane} 10,000 1,379 5,000 0.09

107-15-3 Ethylenediamine {1,2-ethanediamine} 20,000 2,669 0.49

151-56-4 Ethyleneimine {Aziridine} 10,000 1,440 1,000 0.018

7782-41-4 Fluorine 1,000 79 1,000 0.0039

50-00-0 Formaldehyde (Solution) 15,000 1,591 1,000 0.012

110-00-9 Furan 5,000 639 500 0.0012

684-16-2 Hexafluoroacetone 5,000

302-01-2 Hydrazine 15,000 1,918 0.011

7647-01-0 Hydrochloric Acid (>=37% for RMP) 15,000 1,510 0.03

74-90-8 Hydrocyanic Acid {Hydrogen Cyanide} 2,500 434 1,000 0.011

1333-74-0 Hydrogen 10,000 **

10035-10-6 Hydrogen Bromide 5,000

7647-01-0 Hydrogen Chloride (Anhydrous for CAA 112(r )- RMP and PSM)) 5,000 503 5,000 0.03

{Hydrochloric Acid}

7664-39-3 Hydrogen Fluoride/hydrofluoric Acid (>=50% for RMP) 1,000 121 1,000 0.016

{Hydrofluoric Acid}

7722-84-1 Hydrogen Peroxide (>= 52% for PSM) 7,500

7783-07-5 Hydrogen Selenide 500 28 150 0.00066

7783-06-4 Hydrogen Sulfide 10,000 1,308 1,500 0.042

7803-49-8 Hyroxylamine 2,500

13463-40-6 Iron, Pentacarbonyl- {Iron Carbonyl (Fe(co)5), (Tb-5-11)-} 2,500 206 250 0.00044

75-28-5 Isobutane {Propane, 2-methyl} 10,000 2,151

78-82-0 Isobutyronitrile {Propanenitrile, 2-methyl-} 20,000 3,149 0.14

78-78-4 Isopentane {Butane, 2-methyl-} 10,000 1,933

78-79-5 Isoprene {1,3-butadiene, 2-methyl-} 10,000 1,760

75-31-0 Isopropylamine {2-propanamine} 10,000 1,734 5,000

75-29-6 Isopropyl Chloride {Propane, 2-chloro-} 10,000 1,390

108-23-6 Isopropyl Chloroformate {Carbonochloridic Acid, 1-methylethyl Ester} 15,000 1,664 0.1

463-51-4 Ketene 100

78-85-3 Methacrylaldehyde 1,000

126-98-7 Methacrylonitrile {2-propenenitrile, 2-methyl-} {Methylacrylonitrile} 10,000 1,497 250 0.0027

920-46-7 Methacryloyl Chloride 150

74-82-8 Methane 10,000 2,853

74-83-9 Methyl Bromide 2,500
Guidance for Auditing Risk Management Plans & Programs

CAS Chemical Name RMP RMP PSM Toxic

Threshold Threshold Threshold Endpoint

Quantity Corrected Quantity 

(TQ) lbs. to Gals (TQ) lbs

74-87-3 Methyl Chloride {Chloromethane} {Methane, Chloro-} 10,000 1,202 15,000 0.82

79-22-1 Methyl Chloroformate {Carbonochloridic Acid, Methylester} 5,000 489 500 0.0019

{Methyl Chlorocarbonate}

115-10-6 Methyl Ether {Methane, Oxybis-} 10,000 1,655

1338-23-4 Methyl Ethyl Ketone Peroxide (>60% for PSM) 5,000

453-18-9 Methyl Fluoroacetate 100

421-20-5 Methyl Florosulfate 100

107-31-3 Methyl Formate {Formic Acid, Methyl Ester} 10,000 1,235

60-34-4 Methyl Hydrazine 15,000 2,066 100 0.0094

74-88-4 Methyl Iodide 7,500

624-83-9 Methyl Isocyanate {Methane, Isocyanato-} 10,000 1,248 250 0.0012

74-93-1 Methyl Mercaptan {Methanethiol} {Thiomethanol} 10,000 1,343 5,000 0.049

556-64-9 Methyl Thiocyanate {Thiocyanic Acid, Methyl Ester} 20,000 2,244 0.085

79-84-4 Methyl Vinyl Ketone 100

74-89-5 Methylamine {Methanamine} {Monomethylamine} 10,000 1,729 1,000

75-79-6 Methyltrichlorosilane {Silane, Trichloromethyl-} 5,000 472 0.018

13463-39-3 Nickel Carbonyl {Nickel Tetracarbonyl} 1,000 91 150 0.00067

7697-37-2 Nitric Acid (>=80% for RMP) (>=94.5% for PSM) 15,000 1,196 500 0.026

10102-43-9 Nitric Oxide {Nitrogen Oxide (No)} 10,000 943 250 0.031

100-01-6 Nitroaniline {Para Nitroaniline} 5,000

7783-54-2 Nitrogen Trifluoride 5,000

10102-44-0 Nitrogen Oxides (NO, NO2, N2O4, N2O3) 250

10544-72-6 Nitrogen Tetroxide {Nitrogen Peroxide} 250

10544-73-7 Nitrogen Trioxide 250

10102-44-0 Nitrogen Dioxide 250

75-52-5 Nitromethane 2,500

8014-95-7 Oleum (Fuming Sulfuric Acid) (65-80% for PSM) 10,000 608 1,000 0.01

{Sulfuric Acid, with Sulfur Trioxide}

20816-12-0 Osmium Tetroxide 100

7783-41-7 Oxygen Difluoride {Fluorine Monoxide} 100

10028-15-6 Ozone 100

19624-22-7 Pentaborane 100

109-66-0 Pentane 10,000 1,914

79-21-0 Peracetic Acid (>60% Acetic Acid for PSM) 10,000 977 0.0045

{Ethaneperoxoic Acid} {Peroxyacetic Acid}

7601-90-3 Perchloric Acid (>60% for PSM) 5,000

594-42-3 Perchloromethylmercaptan {Methanesulfenyl Chloride, Trichloro-} 10,000 707 150 0.0076

7616-94-6 Perchloryl Fluoride 5,000

75-44-5 Phosgene {Carbonic Dichloride} {Carbonyl Chloride} 500 42 100 0.00081

7803-51-2 Phosphine {Hydrogen Phosphide} 5,000 803 100 0.0035

10025-87-3 Phosphorus Oxychloride {Phosphoryl Chloride} 5,000 364 1,000 0.003

7719-12-2 Phosphorus Trichloride {Phosphorous Trichloride} 15,000 1,142 1,000 0.028

110-89-4 Piperidine 15,000 2,085 0.022

463-49-0 Propadiene {1,2-propadiene} 10,000 **

74-98-6 Propane 10,000 2,381

D-4
D

List of Regulated

Substances

CAS Chemical Name RMP RMP PSM Toxic

Threshold Threshold Threshold Endpoint

Quantity Corrected Quantity 

(TQ) lbs. to Gals (TQ) lbs

106-96-7 Propargyl Bromide {3-bromopropyne} 100

107-12-0 Propionitrile {Ethyl Cyanide} {Propanenitrile) 10,000 1,494 0.0037

627-13-4 Propyl Nitrate 2,500

109-61-5 Propyl Chloroformate {Carbonochloridic Acid, Propylester} 15,000 1,649 0.01

115-07-1 Propylene {1-propene} 10,000 1,968

75-56-9 Propylene oxide {oxirane, methyl-} 10,000 1,395 0.59

75-55-8 Propyleneimine {Aziridine, 2-methyl} 10,000 1,485 0.12

74-99-7 Propyne {1-propyne} 10,000 1,697

107-44-8 Sarin 100

7783-79-1 Selenium Hexafluoride 1,000

7803-62-5 Silane 10,000 1,762

7803-52-3 Stibine {Antimony Hydride} 500

7446-09-5 Sulfur Dioxide (Anhydrous for RMP) 5,000 418 0.0078

5714-22-7 Sulfur Pentafluoride 250

7783-60-0 Sulfur Tetraflouride {Sulfur Fluoride, (Sf4) (T-4)-} 2,500 154 250 0.0092

7446-11-9 Sulfur Trioxide {Sulfuric Anhydride} 10,000 624 1,000 0.01

7783-80-4 Tellurium Hexafluoride 250

116-14-3 Tetrafluoroethylene {Ethene, Tetrafluoro-} 10,000 ** 5,000

10036-47-2 Tetrafluorohydrazine 5,000

75-74-1 Tetramethyllead {Plumbane, Tetramethyl-} 10,000 601 1,000 0.004

75-76-3 Tetramethylsilane {Silane, Tetramethyl-} 10,000 1,849

509-14-8 Tetranitromethane {Methane, Tetranitro-} 10,000 732 0.004

7719-09-7 Thionyl Chloride 250

7550-45-0 Titanium Tetrachloride {Titanium Chloride (Ticl4)(T-4)} 2,500 174 0.02

584-84-9 Toluene 2,4-diisocyanate {Benzene, 2,4-diisocyanato-1-methyl-} 10,000 979 0.007

91-08-7 Toluene 2,6-diisocyanate {Benzene, 1,3-diisocyanato-2-methyl-} 10,000 978 0.007

26471-62-5 Toluene Diisocyanate (Unspecified Isomer) 10,000 1,007 0.007

{Benzene, 1,3-diisocyanatomethyl-}

1558-25-4 Trichloro(chloromethyl)silane 100

27137-85-5 Trichloro(dichlorophenyl)silane 2,500

10025-78-2 Trichlorosilane {Silane, Trichloro-} 10,000 892 5,000

79-38-9 Trifluorochloroethylene {Ethene, Chlorotrifluoro-} 10,000 917 10,000

75-50-3 Trimethylamine {Methanamine, N,n-dimethyl-} 10,000 1,893

75-77-4 Trimethylchlorosilane {Silane, Chlorotrimethyl-} 10,000 1,403 0.05

2487-90-3 Trimethyoxysilane 1,500

108-05-4 Vinyl Acetate Monomer {Acetic Acid Ethenyl Ester} 15,000 1,929 0.26

689-97-4 Vinyl Acetylene {1-buten-3-yne} 10,000 1,689

75-01-4 Vinyl Chloride {Ethene, Chloro-} 10,000 1,237

109-92-2 Vinyl Ethyl Ether {Ethene, Ethoxy-} 10,000 1,579

75-02-5 Vinyl Fluoride {Ethene, Fluoro-} 10,000 1,695

107-25-5 Vinyl Methyl Ether {Ethene, Methoxy-} 10,000 1,542

75-35-4 Vinylidene Chloride {Ethene, 1,1-dichloro-} {1,1-dichlorethylene} 10,000 990

75-38-7 Vinylidene Fluoride {Ethene, 1,1-difluoro-} 10,000 **

D-5


United States

Environmental Protection 

Agency (5104)

Washington, DC 20460

Official Business

Penalty for Private Use

$300